Just got an email from one of our carriers updating us on the (formerly voluntary) "Data Sharing Agreement." For some time, carriers have been "legally permitted to provide eligibility data for its customers' employees to the Centers for Medicare and Medicaid Services (CMS)." [emphasis added]
Come this January 1, however, the "rules of engagement" change dramatically; "the previously voluntary data exchange program will become mandatory and all employers, insurers and plan administrators will be required to share eligibility data with CMS."
And this little gem has teeth:
"Failure to report eligibility data and Social Security numbers...may subject...insurers, third-party administrators, employer and/or plan administrators to civil monetary penalties up to $1,000 for each day of noncompliance for each individual for which data exchange is required."
That could add up to some pretty hefty fines. And these requirements apply to all insured and self-insured groups, large and small. No ERISA skirts to hide behind.
I'm actually okay with this: if nothing else, it should help weed out some of the illegals, and perhaps folks making a run at double-coverage.
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