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Updates to Federal Mandates Affect Employers With Group Health Plans

Overview

Recent changes to two federal health care mandates affect employers who offer health care benefits to their employees through a group plan.

The first mandate describes the Centers for Medicare & Medicaid Services’ (CMS’s) mandatory reporting requirements for all group health plans. The second is known as “Michelle’s Law.” Michelle’s Law ensures up to one year of health care coverage under a parent’s medical policy for seriously ill or injured full-time students enrolled in a post-secondary educational institution.

CMS Mandatory Reporting Requirements

Overview

The Centers for Medicare & Medicaid Services (CMS) has made changes that require group health plans, insurers, and third party administrators (responsible reporting entities) to report certain information to CMS beginning January 1, 2009, to support Medicare Secondary Payer processes.

Background

Earlier this year, we advised you that we are now requesting Social Security numbers (SSN) of the employees, spouses, and (if applicable) domestic partners, regardless of age, for new enrollment effective January 1, 2009. Although CMS has specific submission requirements based on age, we are gathering this information for employees, spouses, and domestic partners at the time of enrollment to eliminate the need for future follow-up with group customers.

To meet the initial CMS requirements, we have identified members enrolled on or after January 1, 2009, for whom we do not have an accurate or complete SSN. Later this year, we will provide you with information about our plan to review and update SSNs for members enrolled prior to January 1, 2009.

What You Need to Do

We communicated with group customers who we identified as having employees with missing or incorrect SSNs. You should have received a letter with an enclosed response form instructing you to review the list, provide correct information, and fax the response form to Enrollment Services at 215-238-7067 by August 31, 2009. Group customers who are registered on the new amerihealthexpress.com portal were asked to provide employees’ SSNs electronically by completing these steps:

  1. Locate the employee by entering the subscriber’s name or SSN in the search box, and clicking the Search button.
  2. From the employee’s record, click the Dependents tab.
  3. Click the Edit button, next to the dependent’s name.
  4. Enter the dependent’s SSN in the SSN field.
  5. After entering the dependent’s SSN, click the Save button.

Our Commitment to Privacy

We are committed to protecting your privacy and that of your employees. We are providing Social Security numbers only to CMS to comply with this new regulation. Furthermore, we will continue to utilize unique subscriber identification on all member identification cards and communications, as we have since 2006.

AmeriHealth takes numerous steps to keep the personal information of our members confidential and to prevent the unauthorized release of or access to this information. All AmeriHealth employees sign annual confidentiality statements regarding member information. All contracted providers are required to maintain confidentiality of member information and records in accordance with applicable laws.

“Michelle’s law”

President Bush signed into law H.R. 2851, “Michelle’s Law,” which will become effective October 9, 2009. This legislation allows full-time college students insured under their parents’ policies to remain covered for up to one year if they are required to take a medically necessary leave of absence from a post-secondary educational institution. This law does not allow the dependent’s coverage to extend beyond the group customer’s maximum age limits. There is no need to take any action regarding Michelle’s Law. This notice is for informational purposes only.