Benefits Buzz

IRS-SSA-CMS Data Match

Posted on July 22nd, 2016

The Internal Revenue Service (IRS), Social Security Administration (SSA), and the Centers for Medicare & Medicaid Services (CMS) are required to share information that each agency has about whether Medicare beneficiaries or their spouses are working. This sharing of information is referred to as the IRS-SSA-CMS Data Match, and the purpose of the Data Match is to identify situations where another group health plan may be primary to Medicare. In general, a group health will be primary to Medicare when:
 
1. The employer has 20 or more employees and the group health plan covers Medicare beneficiaries age 65 and older. In this situation, the group health plan is primary only if coverage under the group health plan is based on the individual's current employment status at an employer or the current employment status of a spouse of any age.  
 
2. The employer has 100 or more employees and the group health plan covers Medicare beneficiaries under age 65, entitled to Medicare as a result of a disability. In this situation, the group health plan is primary only if coverage under the group health plan is based on the individual's or a family member's current employment status with an employer.  
 
3. Group health plans are always the primary payer during the first 18 months of end-stage renal disease (ESRD) based Medicare eligibility or entitlement. This is true regardless of the size of the employer and regardless of current employment status.
 
Under the Data Match Project, employers may receive a notification by mail which requires them to complete an online questionnaire. The questionnaire will request group health plan information on specifically identified workers who are either entitled to Medicare or who are married to a Medicare beneficiary.  The questionnaire will generally ask if named individual(s) worked during a specific time period, and if so, whether they had a group health plan during that time period.
 
Employers that receive a notification must complete the questionnaire within 30 days, unless an extension has been requested. CMS may impose a civil monetary penalty of $1,000 for employers who do not respond to the notifications. In addition, a non-response may result in a subpoena of business records, and the group health plan may be audited to determine if it is complying with the laws that determine when Medicare is the secondary payer of coverage.  
 
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The materials contained within this communication are provided for informational purposes only and do not constitute legal or tax advice. 
 

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