EM Risk Management

Medicare Compliance Deadline is September 30, 2009

8/17/2009

Medicare Compliance Deadline is Looming

Medicare will begin actively protecting its right of recovery against workers' compensation and liability claims using the Medicare Secondary Payer Act and the new Medicare, Medicaid and SCHIP (State Child Heath Insurance Program) Extension Act (MMSEA) passed in December of 2007. Each responsible party must comply with the MMSEA federal reporting requirement or suffer fines and penalties in the amount of $1,000 per day per claim.

EM Risk Management is prepared to coordinate all data capture, transfer, and tracking requirements as mandated by the federal government. EM clients will have all MMSEA reporting requirements met through EM claims administration services. All MMSEA data exchange activity is handled in-house by EM Risk Management. EM is not outsourcing this service to the third party vendor.
Program Registration: From May 1 through September 30, 2009, EM clients will be enrolled as responsible reporting entities (RRE), with EM named as Account Manager/Agent for each client's workers' compensation and/or liability plan.
Medicare requires each RRE sign up as soon as possible to allow a full test period for data transfer. Current testing period for MMSEA data exchange is July 1, 2009 through April 1, 2010. EM account managers coordinate all RRE enrollment activity.

MMSEA FAQs:
1. What is an RRE?
2. Who should be named as the RRE's Authorized Representative?
3. Who is an Account Manager/Agent?
4. Where do I advise Medicare of EM Risk Management as my Account Manager/Agent?
5. When do I register as an RRE?
6. What information is needed to register as an RRE?
7. What do I do after I sign up as an RRE?

What is an RRE?
RRE is a responsible reporting entity - the organization responsible for paying the workers' compensation and/or liability claim. For self-insured organizations, the RRE is the employer or the group self-insurance trust. EM is not an RRE, but can be the Account Manager/Agent for the employer's program.
Employers may have more than one RRE - depending on the insurance/self-insurance programs they have. Following are some scenarios for review - for additional information, please consult the CMS website at http://www.cms.hhs.gov/MandatoryInsRep.

Employer has workers' compensation program with a TPA and the auto liability coverage handled in-house (2 RRE)
Employer has workers' compensation program with TPA and handles medical only claims in-house (2 RRE)

Each RRE will have an Authorized Representative - employers with multiple RRE's can use the same Authorized Representative for each RRE.
If you have questions about how many RRE's you might have, please contact your EM account manager for assistance.

Who should be named as the RRE's Authorized Representative?

The Authorized Representative cannot be anyone from EM Risk Management.
The Authorized Representative will designate the Account Manager/Agent (EM Risk Management).
The Authorized Representative can complete the RRE sign-up with Medicare.
The Authorized Representative must approve the RRE set-up by signing the Data Use Agreement and returning it to Medicare.
The Authorized Representative will be notified if there are compliance issues with MMSEA data exchange.

Who is an Account Manager/Agent?
This is the individual who controls the administration of an RRE's account and manages the overall reporting process. The Account Manager may choose to manage the entire account and data file exchange, or may invite other company employees or data processing agents to assist. EM Risk Management can act as the employer's Account Manager/Agent to manage all data reporting functions with Medicare.

Where do I advise Medicare of EM Risk Management as my Account Manager/Agent?
The employer registers online as an RRE. Employers register online at https://www.section111.cms.hhs.gov/MRA/Login.action. Part of the RRE sign-up designates EM Risk Management as the Account Manager/Agent.

When do I register as an RRE?
Employers can register online between May 1, 2009 and September 30, 2009.
If you have questions about the RRE registration process, please contact your EM account manager for assistance.

What information is needed to register as an RRE?

A Federal Tax Identification Number (TIN) for the RRE
Your Company name and address
Your Company Authorized Representative contact information (name, job title, address, E-mail address, phone, fax)
National Association of Insurance Commissioners (NAIC) company code, if applicable
Reporter Type (choose Liability/No-Fault/Workers' Compensation)
Subsidiary company information applicable to the file submission for the RRE ID (company name, federal tax ID #, NAIC company code for each subsidiary).
Account Manager/Agent information as follows:
- Agent Company Name: EM Risk Management/POMCO
- Agent Contact Name: Bryan Thompson, Quality Assurance Manager
- Agent Company Address: 2425 James Street, Syracuse, New York 13206
- Agent Contact Phone: 315-432-9171
- Agent Contact Fax: 315-433-5473
- Agent Contact E-Mail: bthompson@pomcogroup.com

What do I do after I sign up as an RRE?
Once RRE registration is complete, the Authorized Representative will receive a letter of confirmation via US Mail that will assign an RRE ID (Section 111 Reporter ID) and a PIN. This letter needs to be e-mailed to Bryan Thompson, Quality Assurance Manager at EM Risk Management (bthompson@pomcogroup.com).
EM will then complete the MMSEA registration process. A Profile Report will be e-mailed to the RRE's Authorized Representative when EM's work is complete. The Profile Report requires the signature of the RRE's Authorized Representative and return via US Mail to Medicare before any data testing can begin.

For questions regarding this federal reporting requirement and EM's MMSEA service, please contact your assigned EM account manager.