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The postponed Medicare reporting requirement: what you need to know

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by H. Bernard Tisdale III and Dorothy D. Parson, Esqs.

The Centers for Medicare and Medicaid Services (CMS) recently postponed until next year a requirement that certain partially self-insured employers must report any one-time or lump-sum payments to persons entitled to Medicare benefits. The requirement was to have applied to payments made in connection with settlements, judgments or awards involving the release of potential liability for medical expenses.

Previously, payments that occurred on or after Oct. 1, 2010, were to be reported in the first quarter of 2011. The new deadline requires reporting in the first quarter of 2012 any payments occurring on or after Oct. 1, 2011.

This extension does not apply to payments made to Medicare beneficiaries pursuant to no-fault insurance or workers’ compensation claims. Any such payments occurring on or after Oct. 1, 2010, still must be reported in the first quarter of 2011.

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