Update on CMS Reporting for HRAs
Friday, 07 October 2011 09:02
CMS Changes Reporting Requirement for HRAs
Last week, the Centers for Medicare and Medicaid Services (CMS) announced that the following changes to the reporting requirements for Health Reimbursement Arrangements will be effective on October 3, 2011. So in practice, the changes will apply to plans that begin or renew on November 1, 2011 or later.
Annual Benefit Level Minimum Increases to $5,000
HRA's that provide an annual benefit level of less than $5,000 will no longer need to be reported. Please note that plans that allow rollovers from the previous year's coverage must include the rollover amounts when calculating the current year's annual benefit amount.
Plans that have already been reporting will be required to be reported until their current plan year is over.
New Reporting Required When a Participant Exhausts their HRA Benefit
For employers with plans that are required to report, Chard Snyder will send a notice to CMS when a participant uses their entire HRA benefit.
What do you need to do now?
If your plan is currently being reported to CMS, you will continue to do so until the end of the plan year.
At the beginning of each plan year, Chard Snyder will help you determine whether your plan will need to be reported in the next plan year based on the benefit level offered and any funds that will be rolled over.
How does the reporting process work?
- If it is determined that your plan is required to report, at the beginning of the plan year we will provide you with a census file and time frame for gathering required data.
- The initial file we send to you will contain the census data that we currently have in our processing system. Therefore you may need to gather certain information including member and dependent birth dates, member and dependent social security numbers, and member and dependent legal first and last names and gender.
- Chard Snyder will then forward a production submission file containing your information to CMS.
- Chard Snyder is also required to send quarterly file submissions to CMS with any new or changed coverage information.
Failure to comply with the reporting requirements may result in a penalty of $1,000 each day of noncompliance for each individual who was not reported. This is in addition to any other penalties prescribed by law and any potential claims under the Medicare Secondary Payer regulations.
