GFRG Client Advisory: MMSEA Act of 2007 User Guide 3.1

To view a pdf of this advisory, please click here

The Centers for Medicare and Medicaid Services (CMS) issued Version 3.1 of the User Guide on July 26th. The additions or corrections in this update relate primarily to technical/system issues; however, the following is a summary of the changes in Version 3.1 that may be of interest to our reporting entity clients.

1) Timeframe to Reach Production Status: Section 8.2 has been updated to require that all Responsible Reporting Entities (RRE) are expected to move to a production status within 180 days after initiation of the registration process (the initial registration on the Section 111 reporting website).  There are a number of steps that the Garretson Firm, as your reporting agent, needs to do to complete the testing process, so if you are not in production status, we will be contacting you in the near future.

2) Claim Input File Updates: If the reporting entity has only the Social Security Number for an injured party and after submitting the query request, Medicare provides the Health Insurance Claim Number (HICN), the HICN must now be used going forward.  Sections 11.1.1, 11.10.1 and 12 provide that RREs must store the HICN returned on response files in their internal systems.  GFRG will also store the HICN in your records.

If you have no new information to supply on a quarterly update file, you may, but are not required to, submit an empty Claim Input File.  The option that previously existed to go to the Section 111 website to indicate that there were no claims to report has been rescinded by Medicare.  If you are a Garretson Firm Reporting Agent client, we have a procedure in place to confirm with you that there are no files to report if we have not received any files from you during the quarter.

3) Risk Management Write-offs: CMS issued guidance for Risk Management Write-offs (healthcare write-offs) in their May 26, 2010 Alert.  They have included that guidance in Version 3.1 and it is essentially the same language.  Section 11.10.2 of the User Guide addresses how two defined groups are required to handle write offs and situations where property of value is provided.  One group includes providers, physicians and other suppliers and the second group includes any other entity. Due to the details related to these provisions, GFRG will issue a separate client advisory to explain these provisions.

If you have any questions, please contact us.  Version 3.1 can be accessed at http://www.cms.gov/MandatoryInsRep/03_Liability_Self_No_Fault_Insurance_and_Workers_Compensation.asp#TopOfPage