April 15, 2009 MMSEA Bulletin #2 Important Client Alert Attention Self-Insured and Partially Self-Insured Clients

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April 15, 2009 MMSEA Bulletin #2 Important Client Alert Attention Self-Insured and Partially Self-Insured Clients MMSEA Section 111 Medicare Secondary Payer MMSEA Summary Given the overwhelming amount of information that has been published regarding the requirements of Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007, for your benefit we have summarized the requirements in the attachment to this MMSEA Bulletin #2. Additionally, we have scheduled two webinars which we invite you to join either Wednesday, April 22 nd at 10:30 a.m. or Thursday, April 30 th at 3:00 p.m. (both times are CDT). Please go to http://fara.webex.com, follow the instructions, enter your name, and you will be asked for a password. The webinar password is Fara2009. Once you have logged into the webinar, you will be provided dial-in instructions to take part in the conference call. We will review the basic requirements of the Act and we will respond to audience questions at that time. If you have any questions about this subject and you would like to submit your questions in advance, please contact Laura Tarantino (see below). Decisions to Make Between May 1, 2009 and June 30, 2009, you will need to register on the Coordination of Benefits Secure Web Site at www.section111.cms.hhs.gov/mra to obtain your RRE ID number or numbers. Prior to registering, your company will need to have made the following decisions: 1. For each tax identification number within your organization, how many RRE ID numbers will it need. Are there subsidiaries whose data will be aggregated and reported with its parent entity s data? 2. For each RRE ID number, a. Who will be the Authorized Representative? Note, only one can be associated with each RRE ID. b. Who will be the reporting agent? c. Who will be the Account Manager? Note, only one can be associated with each RRE ID. *See last page Recommendations 2b * FARA is available to assist you with this decision process. Registration Process Once you have determined how many RRE IDs your company will be obtaining, your company will need to register to obtain them.

For each RRE ID you will register to obtain, you will need the following information readily available: Company name, address, phone and fax numbers Federal Tax Identification Number (TIN/EIN) for the company NAIC company code (if applicable) Reporter type (Group Heath Plan or Liability/No-Fault/Workers Compensation) Name, TIN and NAIC company codes for all subsidiaries for which the Company will be aggregating and reporting data Authorized Representative s (AR) name, job title, address, e-mail address, phone and fax number (we suggest using the AR s phone and fax information for the company s phone and fax number as well). TIP: When you begin the online registration process, make sure you have set aside enough time to complete the registration. If you cannot complete it and log off the site in the course of registering, the information you have entered will be lost. The registration process is as follows: 1. Go to the web site: www.section111.cms.hhs.gov/mra The first page will say Login Warning at the top and will look like the screen shot included below. You must read the information on this page and click the I Accept option at the bottom of the page. If you click the Decline option you will not be allowed to register. Each time you log off the web site and log back in you will need to click the I Accept option.

a. The following new screen will appear with the heading Welcome to the Section 111 COB Secure Website (COBSW). For each new RRE ID, you will need to select Step 1 NEW REGISTRATION

b. The following new screen will appear with the heading Account Registration. This screen contains instructions regarding what information you will need to complete the registration process. If you are on this screen, or several of those that follow and need clarification regarding what needs to be provided, a Quick Help button is provided in the upper right hand corner of the page. Once you have completed the form, select the Continue option at the bottom of the page.

c. The following new screen will appear with the heading RRE ID Profile Information. The fields to be filled in are: (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) Company EIN/TIN Number (this is the federal employer identification number /tax identification number issued to the company whose name you include in the next box). Company Name. Enter the legal name of the company who s EIN/TIN you entered in the first box. Company Address. Enter the address of the company. NAIC Number. This is the National Association of Insurance Commissioners (NAIC) company code, if applicable. NOTE: This is not a required field. Company Telephone. We recommend putting in the phone number of the Authorized Representative rather than a general corporate phone number. Company Fax Number. We recommend putting in the phone number of the Authorized Representative rather than a general corporate fax number. NOTE, this field is not required. Reporter Type. GHP means group health plan. Generally those receiving this bulletin will need to select the Liability /No Fault /Workers Compensation option. Once you have completed the form to your satisfaction, click the Continue option at the bottom of the page.

d. The following new screen will appear with the heading Corporate Structure. (i) If the company whose name and EIN/TIN number you entered in the RRE ID Profile Information intends to report the claim files of any of its subsidiaries under the RRE ID it is issued in connection with this particular registration, then include the name, NAIC Number (optional) and EIN/TIN of those subsidiaries. However, if you intend on obtaining an individual RRE ID number for a subsidiary so it may perform its own reporting, do not include them in this screen. Once you have completed this page or if you have no information to report on this page, click Continue at the bottom of the page.

e. The following new screen will appear with the heading Authorized Representative Information. (i) (ii) (iii) Enter the Name, Job Title, E-mail Address, Mailing Address, Phone Number and Fax Number (optional) of the person who will serve as the Authorized Representative for the RRE ID you are requesting. IMPORTANT NOTE, CMS has indicated in a conference call that the E-mail Address must be that of a specifically identifiable person. It cannot be a generic E-mail Address such as AuthorizedRepresentative@Company.com. Once you have completed this page, click Continue at the bottom of the page.

f. The following new screen will appear with the heading Registration Summary. (i) (ii) Review and validate the information summarized on this page. If correct, click Continue at the bottom of the page. The Authorized Representative will receive a letter via US Mail containing a Personal Identification Number (PIN) and the RRE ID associated with that registration. g. The Authorized Representative must provide the RRE ID and PIN number to the Account Manager to perform the account set up. h. Once the Account Manager has completed the account set up, the Authorized Representative will receive an email with the Profile Report which will contain lots of important information. In particular, it will include your assigned production live date and ongoing quarterly file submission timeframe for your MSP Input File and contact information for your Coordination of Benefits Contractor (COBC) EDI Representative. The Authorized Representative must review, sign and return the Profile Report to the COBC. Once COBC receives the signed Profile Report, it will send an email to the Authorized Representative and the Account Manager indicating that testing can begin for that RRE ID.

2. Recommendations a. We recommend that you retain FARA as your reporting agent and obtain a unique RRE ID for the business that FARA will be reporting on. b. We recommend that David Richard, VP of Information Technology, be the Account Manager associated with the RRE ID and that FARA employees serve as Account Designees. c. Finally, there is no advantage to registering early on in the process. Therefore, we advise waiting until sometime in June, 2009 to register. If you have questions, please feel free to call the FARA MMSEA dedicated toll free number at 1-866-719-3272 or email our General Counsel Laura Tarantino, at laura.tarantino@fara.com.