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IRS-SSA-CMS Data Match

Congress enacted a law (Section 6202 of the Omnibus Budget Reconciliation Act of 1989) to provide CMS with better information about Medicare beneficiaries' group health plan (GHP) coverage. The law required the Internal Revenue Service (IRS), the Social Security Administration (SSA), and CMS to share information that each agency had about whether Medicare beneficiaries or their spouses were working.

The process for sharing this information was called the IRS-SSA-CMS Data Match. The purpose of the Data Match was to identify situations where another payer may have been primary to Medicare.

Subsequently, Section 516 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) repealed duplicative Medicare Secondary Payer provisions of the Social Security Act. With this change Section 1862(b)(5) of the Social Security Act was amended to no longer require this information on or after July 1, 2016.'' Consequently, the IRS-SSA-CMS Data Match program has been discontinued. Employers wishing to report outstanding IRS-SSA-CMS Data Match questionnaires or MSP occurrences may contact the BCRC at 1.8555.798.2627.

Historical  Reporting Requirements of Data Match

Employers were required to provide CMS with information regarding health coverage of their Medicare-eligible workers and spouses of Medicare-eligible individuals whenever CMS identified those individuals to the employer. Generally, the questionnaire asked if each named individual worked during a specific time period, and if so, whether he or she had employer-sponsored GHP coverage. Employers were required to respond within 30 days of the initial inquiry, unless an extension had been requested and approved.

Employer Voluntary Data Sharing Agreements (VDSA)

Although the IRS-SSA-CMS Data Match process has been ended, employers should still consider the other benefits of entering into an Employer Voluntary Data Sharing Agreement with CMS to exchange GHP and Medicare entitlement data. Numerous Fortune 500 companies and other large employers have already entered into VDSAs with CMS to share coverage information. As an employer, you too can obtain the substantial benefits produced by entering into a VDSA. For more information on the VDSA program, see the Voluntary Data Sharing Agreement page.

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