As background, in August 2019, the Centers for Medicare and Medicaid Services (CMS) revised its Section 111 Medicare Secondary Payer (MSP) User Guide and issued FAQs that require responsible reporting entities (RREs) to submit primary prescription drug coverage information as part of their Section 111 MSP mandatory reporting requirements effective January 1, 2020.
CMS updated the FAQs with clarifications and two new Q&As 11 and 12. CMS clarified under Q&A 1 that prescription drug coverage reporting does not include individual prescription drugs prescribed to or used by Medicare beneficiaries. Under Q&A 2, CMS clarifies that the effective date of primary prescription drug coverage should be reported, even if the effective date was prior to the 2006 implementation of Medicare Part D. Under Q&A 3, CMS clarifies when an insurer, third-party administrator (TPA), or pharmacy benefit manager (PBM) will be the RRE for a group health plan. Q&A 11 provides information on adding prescription drug coverage reporting to hospital and medical coverage reporting that has already been submitted and accepted. Q&A 12 provides information on reporting requirements for health reimbursement arrangements (HRAs).