New Reporting Requirements for Groups That Self-Administer an HRA or MERP

The Seltzer Group, located in Orwigsburg, Schuylkill Haven and Pottsville, provide extensive Group Health and Human Resource services.  For more information, please visit www.seltzergrp.com.

Last year, the Centers for Medicare and Medicaid Services (CMS) began requiring reporting from Group Health Plans (GHPs) identifying situations where the plan is (or has been) the primary payer and Medicare is (or has been) the secondary payer.  CMS provided an extension on reporting HRA information until the 4th quarter of 2010. Employers who administer HRAs or MERPs that meet a specific criteria are required to register with CMS and begin to submit quarterly reports for their first plan year after October 1, 2010.

Registration for HRA/MERP reporting is now available and must be completed by June 30, 2010.

To register, please visit: www.Section111.cms.hhs.gov.  

Criteria for Determining if a Group is Required to

Register its HRA or MERP plan:

HRA or MERP plans will be required to register with CMS if ALL of the following criteria apply:

  • The plan has an annual benefit value of $1,000 or more (an employee covered by the plan could be reimbursed for $1,000 or more in claims).
  • The employer has 20 or more employees (and is subject to the Medicare Secondary Payer requirements).  To determine applicability of these requirements, all employees, not just those on the health plan, are counted. 
    • Please note that if the employer has less than 20 employees and an employee or dependent has end stage renal disease (ESRD), the plan MUST report regardless of the number of employees.
  • The plan reimburses employees for medical claims. 
    • Please note that if the plan reimburses for dental and/or vision benefits ONLY, no reporting is required.
  • The employer pays all claims and does not have an outside claims administrator.
New Reporting Requirements for Groups That Self-Administer an HRA or MERP was last modified: August 26th, 2014 by Sarah McGorry