The Centers for Medicare & Medicaid Services ("CMS") has revised the timeline for non-group health plan ("NGHP") reporting under the Medicare secondary payer reporting provisions of Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 ("Section 111"). Section 111 requires all payments by insurers to Medicare beneficiaries to be reported to CMS in order to ensure that Medicare does not reimburse beneficiaries a second time for their medical benefits.

For payers of claims for liability insurance (including self-insurance), no-fault insurance and workers' compensation, all "responsible reporting entities" ("RREs") had been required to begin submitting claim files to CMS's Coordination of Benefits Carrier between April 1, 2010 and June 30, 2010, based upon a predetermined schedule. That April 1, 2010 reporting date has now been postponed until January 1, 2011. The delay in implementation will allow CMS to continue addressing the surprising number of policy and technical questions that are still being raised by carriers and others in CMS's ongoing series of Town Hall Teleconferences.

CMS said that it would post the next version of the "Section 111 NGHP User Guide" and a number of policy alerts this week.