Group health plans must report to the Centers for Medicare and Medicaid Services (CMS) Social Security Numbers or Medicare Insurance Claim Numbers for employees and their covered family members who might have Medicare coverage in addition to coverage under the employer group health plan. Many employers with fully-insured health plans have been contacted by their insurers to collect SSNs and HICNs for their participating employees. Self-funded plans may have their own reporting requirements. The reporting, required under Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007, helps CMS identify Medicare-covered individuals with group health plan coverage that should pay claims primary to Medicare.
There is also a reporting responsibility for liability insurance, no-fault insurance and workers' compensation coverage. This obligation creates additional reporting obligations for legal settlements, judgments and awards involving Medicare beneficiaries.
Requests from insurers for employee Social Security Numbers should not be ignored as penalties may be imposed on non-reporters.
