GRG Client Advisory: Direct Data Entry Option

To download a pdf of this advisory, please click here.

The Centers for Medicare and Medicaid Services (“CMS”) included an alternative, in Version 3.1 of the User Guide, for the traditional reporting under the provisions of Section 111.  This alternative is called the Direct Data Entry (DDE) option; and allows small Responsible Reporting Entities ("RRE") to be able to report to the Coordination of Benefits Contractor ("COBC") without using a reporting agent or doing their own programming.  This alert defines a "small reporter" as an RRE that will submit 500 or fewer NGHP claim reports per calendar year. CMS emphasizes that the direct reporting option is very limiting and suggests that the following should be considered before using this option:

• No ability to query for entitlement
  
  • Reporting entity will not be able to determine entitlement prior to settlement to start
    compiling/requesting the required information for reporting;
• Injured party information will be matched real-time online as it is entered on the COBSW;
  
  • Medicare entitlement will be provided post settlement when the data points are being
    entered for settlements already agreed to
• Claims must be reported within 45 days of the settlement or of assuming ORM
• Once the RRE enters information about the claim, they can save and return, but must
  complete within 30 days.
• All of the same data elements must be entered, but they are entered manually
  
  • There is the risk of a data entry error since someone will have to enter information into
    each field
• All entries into the system will count toward the 500, so if the RRE has a significant
  number of claims, but few that are for Medicare beneficiaries, they could hit the 500 limit
• RRE can’t register as an RRE until October 4, 2010
• There will be no assistance from Medicare/COBC with what claims need to be reported, 
           what the fields mean, what are the correct ICD-9 codes, etc.

If you have any questions about this option, please contact us.  Version 3.1 can be accessed by clicking here.