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On May 11 the Centers for Medicare & Medicaid Services (CMS) announced another extension of the timetable for the Mandatory Insurance Reporting (MIR) requirements under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation plans (non-GHP plans). The major changes were that the registration period, the testing period window, and live production file submissions were all extended by three months. The new implementation timetable for non-GHP responsible reporting entities (RREs) is now:

01/01/09-06/30/09 Recommended systems development period (no change).
05/01/09-09/30/09 Electronic registration of RREs (previously 5/1/09-6/30/09).
07/01/09 Query function available for test and production files (previously not announced).
01/01/10-03/31/10 Testing period for claim input file (previously 10/1/09-12/31/09).
04/01/10-06/30/10 Initial production claim input file submissions due (previously 1/1/10-3/31/10).
06/30/10 All RREs will be submitting live production files by this date (previously 3/31/10).

MMSEA Background

In December 2007 Congress enacted the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA). Section 111(b)(8) amended the Medicare Secondary Payer (MSP) statute to provide for mandatory insurer reporting by liability insurance (including self-insurance), no-fault insurance, and workers’ compensation plans. The purpose of these amendments, as expressed by its sponsor, Senator Chuck Grassley (R-IA), on the floor of the Senate, is to “improve the Secretary’s [of CMS] ability to identify beneficiaries for whom Medicare is the secondary payer by requiring group health plans and liability insurers to submit data to the Secretary.”

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