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HCA reporting guidance

Affordable Care Act (ACA) guidance

Employer shared responsibility

This section contains general information about legal and tax matters. The information is not legal or tax advice and should not be treated as such. You should not rely on this information as an alternative to obtaining legal or tax advice from a licensed attorney or tax specialist. We encourage you to consult with your legal or tax advisors on all aspects of the ACA and how it will impact you as a unique employer.

Health Benefit Exchange

Information reporting by large employers on health insurance coverage offered under employer-sponsored plans

Information reporting of minimum essential coverage

Guidance

IRS forms

Tax-related guidance

Medicare secondary payer and Data Match

Learn about the process a PEBB organization needs to take when Medicare bills the organization directly to recover costs considered payable through employer-sponsored coverage.

How does MSP work?

If Medicare pays primary for an employee or enrolled family member, Medicare may bill a PEBB organization directly to recover costs considered payable through the employer-sponsored coverage. Medicare holds employers primarily responsible for resolving MSP cases.

As stated in the initial demand packet you may not transfer this responsibility to the group health plan (GHP), its insurer, or any other entity. Although the Health Care Authority (HCA), PEBB, and the health plan can provide help in resolving these cases with your permission, Medicare ultimately holds the PEBB organization responsible.

What do we do?

The initial notices must be processed quickly but they do take time to research. Since we began our Voluntary Data Sharing Agreement (VDSA) with Medicare we have been able to dramatically reduce the number of MSP cases and are reporting the PEBB mailing address to Medicare so we can receive correspondence directly. Hopefully you will not see these demands for payment from Medicare. If you do, use the following process to resolve the MSP case.

Follow the MSP process to avoid penalty

The Centers for Medicare & Medicaid Services (CMS) Medicare Coordination of Benefits and Recovery (COB&R) and their Commercial Repayment Center (CRC) is the contractor for Medicare that issue demands for payment on MSP cases. If you receive a Medicare Secondary Payer Demand Packet from CMS and the COB&R, to avoid a penalty:

  • Immediately send all MSP notices (including secondary notices) along with the letter indicating the dates the employee and/or covered family members were eligible for PEBB coverage to:
    • HCA/PEBB
      Attention: Outreach & Training
      PO Box 42684
      ​Olympia, Washington 98504-2684
  • If you have questions regarding MSP notices, please email HCAPEBO&TPSTeam@hca.wa.gov.

Be timely: 60-day window until collection begins

Timing is extremely critical on these demand packets. It is imperative that these do not sit on someone’s desk without action. CMS COB&R has good information on their Group Health Plan Recovery webpage. Please make sure that you have a primary and secondary person who understands the process and can respond within the timeframes outlined in the letters you receive from CMS COB&R. Unless an MSP case is resolved by full payment or a valid defense within 60 days, interest on the debt begins to accrue on day 61. Partial payment or partial defense does not stop the timeline.

What happens if we miss the deadline?

On day 61 an Intent to Refer (ITR) letter is generated giving notice that it is the intention of the CMS COB&R to refer the debt to the US Treasury for collection. You can still mount a defense to the ITR letter, but if full payment or valid defense is not received by day 240, the debt is referred to the US Treasury.

Federal law allows the US Treasury to collect on unresolved debts and if you receive federal funding for any program, they can intercept those funds to satisfy an MSP debt. This has happened in recent years to a number of agencies. It is crucial that these cases be resolved quickly. Once a case gets to the US Treasury for collection, you have only 10 days to dispute the debt before Treasury can start collecting. Once the funds are taken from your agency it is a long, tedious, and near impossible task to recover those funds.

It cannot be over-emphasized the importance of getting these resolved within the first 60 days, if possible. This may mean that you need to train anyone receiving mail in your organization to:

  • Recognize any of these letters sent by the CMS COB&R or the US Treasury.
  • Handle them with the highest priority.
  • Get them to the right person in your organization to contact Outreach & Training at HCA.

Notes:

  • On the US Treasury letters or letters from one of their private collection agencies, they assign their own identification number and they do not list the name of the individual in the collection notice. You will need to contact Outreach & Training for help with this.
  • Medicare data match requests must be completed by the employer.

2011 - present

Plan name and address

Tax ID

DeltaCare
(administered by DeltaDental of Washington)
P. O. Box 75688
Seattle, WA 98125-0688

91-0621480

Kaiser WA Classic, Value, SoundChoice, and Medicare
601 Union St, Suite 3100
Seattle, WA 98101-1374

91-0511770

Kaiser WA CDHP
601 Union St, Suite 3100
Seattle, WA 98101-1374

91-1467158

Kaiser Permanente NW Classic, CDHP, and Medicare
500 NE Multnomah St. Suite 100
Portland, OR 97232-2099

93-0798039

Premera Blue Cross
7001 – 220th St. SW
Mountlake Terrace, WA 98043

91-0499247

Uniform Medical Plan (Classic, CDHP, UMP Plus and Medicare)
(administered by Regence Blue Shield)
P. O. Box 2998
Seattle, WA 98401-2998

91-0282080

2008 - 2010

Plan name and address

Tax ID

Aetna Public Employee's Plan
1400 One Union Square
600 University St.
Seattle, WA 98101

91-1315815

Kaiser Permanente (Value)
500 NE Multnomah St. Suite 100
Portland, OR 97232-2099

93-0798039

Uniform Medical Plan
P. O. Box 34850
Seattle, WA 98124-1850

91-1412780

2007 and prior

Plan name and address

Tax ID

Aetna U.S. HealthCare of Washington, Inc.
(formerly NylCare)
600 University Street
Suite 1400
Seattle, WA 98101-1158

91-1662406

Aetna U.S. HealthCare, Inc.
(formerly Virginia Mason Health Plan)
601 Union Suite 800 Two Union Square
P.O. Box 91032
Seattle, WA 98111-9132

91-1315815

Group Health Options
320 Westlake Avenue N, Suite 100
Seattle, WA 98109-5233

91-1467158

Kitsap Physicians Service
400 Warren Avenue
P.O. Box 339
Bremerton, WA 98337

91-0540525

Northwest Washington Medical Bureau
(merged with Regence Blue Shield)
333 Gilkey Road
Burlington, WA 98233-2823

91-0365690

PacifiCare of Washington, Inc.
7525 SW 24th Street
Mercer Island, WA 98040

97-1312551

Premera HealthPlus
P. O. Box 327
Mailstop 215
Seattle, WA 98111-0327

91-0499247

Premera HealthPlus
(merged with Premera Blue Cross)
7001 – 220th Street SW
Mountlake Terrace, WA 98043

91-1135721

Providence Health Plans
(formerly SelectCare)
1338 Commerce, #300
P.O. Box 370
Longview, WA 98632

93-0835456

QualMed Health Plan
2331 130th Avenue NE, Suite 200
P.O. 3387
Bellevue, WA 98009-3387

91-1584790

Regence Classic
1800 Ninth Avenue
Seattle, WA 98101-1322

91-1135721

Regence BlueShield Columbia Dental
1800 Ninth Avenue
P.O. Box 21267
Seattle, WA 98111-3267

91-0282080