From Feb 2011 through Mar 2012 the Government Accountability Office (GAO) audited and reviewed how the initial implementation of Section 111 mandatory insurance reporting for Non-Group Health Plans (NGHP’s) has affected Medicare savings and the Medicare reimbursement process. The GAO recently submitted their findings in a March 2012 report to a House Congressional Committee. The report discusses steps the CMS is taking to address challenges mandatory reporting has caused. The GAO then gives recommendations to the CMS on how to enhance services to make the MSP system more efficient.
The GAO identified the following problem areas within the MSP process:
- Poor guidance and communication about the MSP system itself
- There is very little guidance for Liability Medicare set-aside arrangements
- Poor communication with beneficiaries regarding their rights and responsibilities.
- “That the Acting Administrator of CMS review recovery thresholds periodically for appropriateness to ensure that the agency’s recovery efforts are being conducted in the most cost-effective manner possible, and not require NGHP’s to report on cases for which the agency will not seek any recovery.
- To potentially decrease the administrative burden of mandatory reporting for NGHPs, the GAO recommend that the Acting Administrator of CMS consider making the submission of ICD-9 codes an optional component of reporting for liability NGHPs.
- Develop a centralized MSP program website to include links to information about the various parts of the MSP process;
- Develop guidance regarding liability and no-fault set-aside arrangements; and
- Review and revise the correspondence with beneficiaries, such as letters sent during the recovery process, to ensure that beneficiary rights and responsibilities are more clearly communicated.”
Stay tuned to see if the recommendations take hold. It will be interesting.