The PAID Act is Now Live – A New Era of MSP Compliance Starts


Under this new law, the Centers for Medicare and Medicaid Services (CMS) is required to provide non-group health plan (NGHP) Responsible Reporting Entities (RREs) with certain information regarding a claimant’s enrollment in a Medicare Part C (Medicare Advantage) and/or Medicare Part D (Perscsription Drug) plan through CMS’ Section 111 Query Process system.  Signed into law last December, CMS was required to implement the PAID Act’s provisions by December 11, 2021.  Since June, CMS has taken several steps to meet this deadline, including making the necessary changes to the Section 111 Query Process, updating its Section 111 NGHP User Guide, and establishing a voluntary PAID Act testing period. 

In the bigger picture the PAID Act’s enactment and CMS’s timely implementation of the new law, are major developments (and accomplishments) and start a new chapter on the Medicare Secondary Payer (MSP) compliance front. 

Going forward

With the PAID Act live, focus now shifts to how smoothly the data exchange between CMS and RREs will go and the accuracy of the information CMS provides.  In addition, it will be interesting to see if, and to what extent, RREs will use the data points CMS provides to proactively address Medicare Advantage and Part D recovery claims and avoid potential “double damages” lawsuits.

Over the past year ISO Claims Partners has been at the forefront of keeping the industry updated on the PAID Act and CMS’s steps toward implementing this new law. Going forward, we will continue to monitor events related to the PAID Act and provide updates as warranted.

In the interim, with the PAID now implemented, we have updated our recent article (to include a new title to reflect that the PAID Act is now effective) entitled: The PAID Act is now live – 5 things you need to know (and how we can help!)  -- this article provides an excellent overview of the PAID Act, how it impacts MSP compliance, and how we can help you take advantage of the data you will receive from the PAID Act to minimize risk and get claims settled.   


Please do not hesitate to contact the author if you have any questions or would like to set up a call to learn more about how we can help you!

By Mark Popolizio

Courtesy of Verisk

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