Centers for Medicare and Medicaid Services Policy Update
It is advised that all employers, regardless of whether they have current Medicare-eligible employees, be aware of the effect that Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) has on the mandatory reporting of Social Security numbers of their employees. This new federal law adds new mandatory reporting requirements for group health plans. These regulations and their subsequent reporting components will become effective on a phased basis beginning in 2009 and will affect all employers.

In order to comply with these new requirements, Blue Cross Blue Shield of Massachusetts is now mandated to report member Social Security number information to the Centers for Medicare and Medicaid Services (CMS) on a quarterly basis.

While Blue Cross Blue Shield of Massachusetts, through its previous voluntary collection and reporting efforts with CMS, has Social Security number information for many of its members, we do not have it for our entire member population. In order to meet the additional mandatory reporting requirements, Blue Cross Blue Shield of Massachusetts plans to reach out to members who meet the reporting criteria for whom we do not have the required information on file. For some members, we will be conducting a survey to acquire this information. This approach will be used on an interim basis until an ongoing data collection strategy has been developed and implemented.

Should your employees receive a communication requesting this information, they will be advised that they must return this information within a specified time frame. Consistent with our existing data security policies, all information will be handled securely and with the utmost care. It is imperative that employees respond to the communication in order to comply with the federal law. Blue Cross Blue Shield of Massachusetts appreciates your support in communicating this message to your employees and in assisting us in capturing the required data.

In the future, we will advise you of our approach to collecting the additional MMSEA group health plan data reporting requirements. This includes reporting of Taxpayer Identification Numbers (TINs) for all groups that meet the requirements set forth in the regulation. These data need to be reported on a quarterly basis to CMS, beginning January 1, 2010.

Blue Cross Blue Shield of Massachusetts is evaluating whether changes to our existing account agreements will be necessary. Please contact your account executive if you have any questions about this new regulation.

For additional information regarding this new federal law, please visit the CMS website at www.cms.hhs.gov/MandatoryInsRep.