Medicare is told who your group plan covers, and it needs accurate data from you to do it.
Section 111 requires insurers and plan administrators to report to CMS every Medicare beneficiary covered under a group health plan, so Medicare knows whether the plan pays first. Employers rarely file anything themselves, but a carrier can only report what the employer gives it.
The carrier or administrator files, not usually the employer.
The reporting obligation sits with a responsible reporting entity.
Insured Plans
The insurer is the responsible reporting entity. It submits the data to CMS and depends on the employer’s enrollment files for the details.
Self-Funded Plans
A third-party administrator can serve as the reporting entity. For a self-insured, self-administered plan, it is the plan administrator or fiduciary, which makes the employer responsible directly.
Responsibility Stays Put
A reporting entity can use an agent to submit its files, but it remains responsible for accuracy. An employer can’t hand off the data problem to a vendor and forget it.
Quarterly, in electronic files.
Reporting covers employees and dependents who are Medicare beneficiaries and have group coverage that may be primary to Medicare.
The Data
Identifying information such as Social Security number or Medicare Beneficiary Identifier, coverage dates and employee status. CMS uses it to match its records.
The Rhythm
Files go to CMS each quarter. CMS also offers an optional response file so a plan can learn which of its members Medicare has on record.
Penalties
The statute provides for civil money penalties against reporting entities that fail to report. Most employers avoid the exposure by keeping enrollment data clean.
Keep the data clean and know who files.
The practical work for an employer is small, and mostly about enrollment records.
Collect What Is Needed
Make sure enrollment captures the identifying information the carrier asks for, for employees, spouses and any dependent on Medicare, and that updates flow through promptly.
Know Who Is Filing
Ask the carrier or administrator to confirm in writing who the responsible reporting entity is and how they handle files. Self-funded employers should be clear on this before the plan year starts.
Watch the Size Tests
Whether the group plan pays first depends on employer size and the reason for Medicare entitlement. Employees who turn 65 and keep working need the decision made correctly at enrollment.
What employers ask about Section 111 reporting.
Does the employer file with CMS?
Usually not. The insurer or administrator is the reporting entity. A self-insured, self-administered plan is the exception, and then the plan administrator reports.
Why does the carrier ask for Social Security numbers?
CMS matches on identifying numbers, so carriers need them for Medicare-eligible participants. Employers should collect them securely.
Does this change who pays first?
No. Section 111 is about reporting. The Medicare Secondary Payer rules decide who pays first.
Related guides.
Medicare Secondary Payer Rules
Who pays first when someone has both.
COBRA and Medicare
How the two interact at termination and retirement.
Michigan Compliance Calendar
Annual deadlines in one place.
Tell us how your enrollment data flows.
We’ll tell you who reports for your plan, what data the carrier needs from you, and where your records tend to fall short. No cost, and no obligation.
Your carrier or administrator
Whether the plan is insured or self-funded
Employees age 65 or older
How enrollment changes reach the carrier
Rough answers are fine. We build the numbers from there.
Laws and rules referenced
CMS: Mandatory Insurer Reporting for Group Health Plans — Responsible reporting entities, quarterly reporting and registration.
42 U.S.C. § 1395y(b)(7) — Medicare Secondary Payer reporting requirement for group health plans.
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