The Catholic University of America

Finance: Accounting
Mandatory Medicare Reporting 

Approved by: President
History: Issued    -- October 27, 2009  
  Revised  -- May 12, 2010  
Related Policies: Information Security and Assurance Policy
Additional References:  
Responsible Official: General Counsel  tel. (202) 319-5142

I.     Introduction

Federal law requires any education institution or business that is self-insured for any portion of its no fault medical payment coverage to report certain payments made to satisfy a claim involving medical treatment to the Centers for Medicare and Medicaid Services (CMS).

II.    Definitions

A. Covered Payments are defined as any payments made to a Medicare recipient, including partial payments and payments made as settlements, judgments or awards for a personal injury that requires medical services, including mental health claims and prosthetic device claims.

III.   Responsibilities of Educational Institution

The mandatory reporting thresholds are $5,000 for payments made on or after January 1, 2011, $2,000 for payments on or after January 1, 2012, and $600 for payments on or after January 1, 2013. Any covered payments to a Medicare recipient must be reported if it meets the threshold amount noted above.

The University has registered as a responsible reporting entity. The Authorized Representative is the General Counsel. The Account Manager is the Records Manager for the Office of General Counsel and the Account Manager will be responsible for the quarterly filings required under this law.

The Authorized Representative will sign any necessary contracts required under the reporting requirements and holds ultimate responsibility for the University's compliance with the reporting requirements. The Authorized Representative will also draft procedures for meeting the reporting requirements under this law.

Data collection is necessary for covered payments. Data to be collected by the Account Manager for any potential payee is as follows: Social Security Numbers (or if no SSN, then the Health Insurance Claim Number), date of birth, gender, name and address for all claimants. The Account Manager will work with the Risk Manager and the Director of Accounts Payable to ensure that any covered payment being reviewed or paid will not be made until collection of this data has occurred.

The Office of Technology Services will assist the Account Manager with any necessary testing of the Electronic Data Interchange and will work with the Office of General Counsel to assure compliance with the University's Information Security and Assurance Policy. Workers' Compensation Payments will be made directly to CMS by the Workers Compensation carrier and are not the responsibility of the University.