Medicare Secondary Payer Mandatory Insurer Reporting

The Medicare Secondary Payer Mandatory Insurer Reporting (MSP-MIR) requirement of Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) includes a Group Health Plan (GHP) requirement that obliges health plans to report certain information to the Centers for Medicare & Medicaid Services (CMS). CMS is the federal agency that regulates the Medicare program.

The purpose of this reporting process is to enable CMS to more effectively pay for the health insurance benefits of Medicare beneficiaries who have coverage under group health plan arrangements.  

In order to comply with this mandatory request Health Net needs some data from their small business & mid-market group customers that they have not previously collected.

Group Data Needed:
  1. Group legal name, if different than the name noted in their current Health Net Group Service Agreement.
  2. Tax Identification Number (TIN).  
  3. Total number of employees company wide — includes fulltime and part time employees — in the range that applies: 1-19, 20-99 or 100 or more.

Social Security Number Collection
The MSP-MIR requirement also specifies that Health Net provide Social Security Numbers*  for members who meet any one of the following criteria:
  • Active employees and dependents who are age 45-64;
  • Members 65 and older who have coverage based on their own — or a spouse's — current employment status;
  • All group members of any age who are receiving kidney dialysis or have had a kidney transplant; and
  • All active employees and dependents who are under age 45 and who are known to be entitled to Medicare.

Health Net's Part
Health Net will be sending a mailing to their customers the week of August 17th requesting the group data and missing Social Security Numbers for covered dependents age 45 and older. In addition, brokers will receive a notice about the mailing to employer groups. Copies of the letters and form are attached for your reference:

Customers simply fill in the form and return it directly to Health Net in a pre-paid envelope on or before September 15, 2009.

Going forward, both Subscriber and Dependent SSNs will remain required fields on Health Net's enrollment forms. To assure continued compliance with this new reporting requirement and to minimize future requests for missing data, Health Net is asking their groups and brokers for their help. Prior to sending enrollment forms to Health Net, they are being asked to ensure the  SSNs are included –  particularly for members and dependents age 45 and older.  


* State laws that restrict the collection of SSNs do not apply in this case. Provisions of the federal Medicare as Secondary Payer (MSP) or Medicare Modernization Act (MMA) regulations or the “permitted use” provisions of the HIPAA privacy rules allow the collection and use of SSNs to help providers and insurers manage their operations. For more information about MSP reporting, please see the CMS website: http://www.cms.hhs.gov/MandatoryInsRep/.