Qualities of a Successful Reporting Agent
Many Responsible Reporting Entities (RREs) have contracted with Reporting Agents for exchange of Section 111 Mandatory Insurer Reporting (MIR) data with the Center for Medicare and Medicaid Services (CMS). However, as we approach the 4th quarter of 2011, and the first quarter of 2012 is looming in the not too distant future, RREs should be preparing to report liability claims to CMS, perhaps for the first time. This is the perfect time for RREs to re-evaluate their relationship with their current Reporting Agent.
Some Reporting Agents may claim mastery or successful CMS MIR submissions but are they merely an “official reporting representative” or do they offer additional key value as partner in Medicare compliance?
Here are 5 key attributes of a good Reporting Partner:
- Technical Processes
- Compliance Tools
Some RREs self administer claims and may also utilize third party claim administrators to handle and report claims. A Reporting Partner should be capable of consolidating data from multiple data sources and/or differing data types and formats. This flexibility is critical to expedient implementation of timely reporting. Does your Reporting Agent require you to register and maintain several RRE IDs due to lack of this flexibility?
Selecting claim records for timely initial and subsequent MIR submission per CMS requirements and event tables is a difficult process. A Reporting Partner provides automated file selection and reporting of customer submitted, qualified claim records for quarterly reporting. What are your Reporting Agent’s automated and manual processes for CMS Section 111 Reporting and submission to CMS? Should the Reporting Agent filter, change or modify customer data prior to CMS submission, do you know what’s been changed? Is your claim, risk or matter management system still the system of record?
Provision of CMS threshold communications and record acceptance rates assist RREs with compliance performance information only after data has been submitted to and processed by CMS. A Reporting Partner empowers customers by providing management tools and data validation prior to proactively managing CMS submissions and MIR performance. Reporting Agents provide Query and Claim Responses from CMS, is this enough?
Where CMS Section 111 reporting identifies RREs as the primary payers, Medicare Secondary Payer (MSP) compliance issues (such as exposure to conditional payments) may arise requiring timely recommendations and services. A Reporting Partner offers its customers a selection of MSP compliance plans which allow for proactive identification of exposure and assignment of services designed for the customers desired handling procedures. Does your Reporting Agent have the capability to identify MSP exposure or the expertise to provide necessary services for proactive MSP compliance?
Communication regarding customer data and CMS processing is critical to successful MIR performance. Questions ranging from field definitions, data mapping, operations training and responses to CMS should be easily resolved via e-mail or telephone. A Reporting Partner provides central points of contact regarding technical, operational and legal questions for expedited communication and response. If you currently have a question or issue, do you have a single point of contact at your current Reporting Agent you would call?
MIR requirements, definitions, and specifications continuously change as CMS becomes more familiar with the industry and what data they wish to collect. A Reporting Partner is one who actively participates in special programs, CMS Town Hall teleconferences, is an industry advocate, and supports groups to build relationships, expertise and drives results. Is your Reporting Agent passive, passing along CMS Alerts and memoranda and simply responding to change?
The customer and RRE faces exposure in complying with MMSEA Section 111 Reporting and the MSP Act. How well does your Reporting Agent perform and what have they done for you lately?
These 5 attributes should help you determine whether your Reporting Agent is measuring up to the exacting standards that compliance requires and if they are ready for to begin reporting liability claims to CMS at the beginning of the first quarter of 2012.
About the Author: John Miano is the Manager of Reporting Services for Gould & Lamb, LLC. His primary responsibility is directing the implementation of CMS Section 111 reporting programs for our clients. He has over 20 years experience in the Property and Casualty Insurance Industry and is currently an active committee member of the International Association of Industrial Accident Board Committees (IAIABC). He is also a former Executive Board Member of the Association of Workers Compensation Claim Professionals (WCCP) and is a Board Certified Workers Compensation claim adjuster (CWC).