As you may be aware, Group Health Plans have a requirement to report to the Centers for Medicare & Medicaid Services (CMS) the Social Security Number of any employee or dependant 45 years of age or older or for any covered participants known to be entitled to Medicare regardless of age.  

The purpose of the reporting process is to enable CMS to correctly pay for the health insurance benefits of Medicare beneficiaries by determining primary versus secondary payer responsibility. In most cases, the insurance carrier reports this information to CMS.  

This requirement has now been extended to Health Reimbursement Arrangement (HRA) plans, which are also considered group health plans.  As a Third Party Administrator, BenefitHelp Solutions will be fulfilling the HRA plan reporting requirement to CMS on our clients' behalf, as the responsible reporting entity (RRE).

HRA plans are self-funded by the employer.  Self-funding groups (ASOs) will be responsible for any fines resulting from noncompliance within their group.  CMS will fine employers $1,000 per member per day for any missing or incomplete Social Security Numbers.  By working together, we can ensure that CMS receives all of the required numbers and employers won't be affected.

CMS is requiring that all responsible reporting entities collect Social Security Numbers for certain HRA participants and their covered dependants because of an act passed by Congress in late 2007 and now expanded to cover HRA plans.  We must meet CMS' deadline to avoid stiff penalties.  Groups that cannot make the September 24, 2010 deadline are asked to contact their FSA Group Specialist.

If you would like more detailed information about why CMS is requiring social security numbers, please visit the CMS website at: http://www.cms.gov/MandatoryInsRep/.