Employers may receive a request from the Centers for Medicare & Medicaid Services (CMS) prompting the submission of group health plan information to support the IRS/SSA/CMS Data Match Project. The Data Match Program is designed to facilitate shared access to data between the Internal Revenue Service (IRS), the Social Security Administration (SSA), and CMS. The shared data allows each agency to pool information on Medicare beneficiaries who also have coverage under a group health plan, and make determinations as to the coordination of benefits between the two. Cooperation by employers is required by law, and the failure to properly respond to the request within 30 days of receipt may result in the imposition of penalties in the amount of $1,000 per individual listed in the letter.
Reason for the Request
Most often, an employer will receive a Data Match Request because a group health plan participant who also has Medicare coverage incurred medical expenses and submitted claims. In this instance, Medicare will need to determine whether it should pay the claim as primary or secondary to the group health plan according to Medicare Secondary Payer Rules. CMS acknowledges that the request may be burdensome to some employers, but promotes the cost savings to employers, Medicare beneficiaries, providers, and Medicare as a worthy cause.
The information requested for the Data Match is not exhaustive. Employers must provide group health plan information on specifically-named individuals (either an employee or a spouse). Employers will need to confirm that the named individual was employed and/or covered under the group health plan at the time a claim was incurred. Additional information about the type of coverage is also required.
How to Submit the Data
Submissions may be made online at the IRS/SSA/CMS Data Match Secure Website, either through the direct entry of data or through an electronic questionnaire. Employers also have the option to request a 30-day extension of time to submit the requested data. Instructions on how to complete the Data Match can be found here, along with information on Voluntary Data Sharing Agreements that an employer may enter into with CMS in lieu of completing future Data Match Requests.