New regulation requires Social Security Numbers for medical plan members

In late 2007, Congress passed the Medicare, Medicaid, and SCHIP Extension Act. As part of the act, the Centers for Medicare and Medicaid Services (CMS), a governmental organization that oversees Medicare and Medicaid plans, is now requiring all health insurance companies nationwide to collect Social Security Numbers for certain medical plan subscribers and certain dependents.

In addition to Social Security Numbers, ODS must report other subscriber, dependent and employer status information to CMS, such as the employer’s tax identification number, number of employees and information regarding the subscriber‘s employment status.

ODS plan

ODS is developing a plan to meet this requirement. We have begun collecting Social Security Numbers for all ODS medical plan subscribers, their spouses or partners and certain dependents enrolling or renewing as of Jan. 1, 2009. We started collecting Social Security Numbers for certain existing members on Feb. 2, 2009. We will share the details of our communication efforts with you as they become available.

Deadline and penalties

The purpose of this regulation is to ensure that proper coordination of benefits is applied to individuals who have group health insurance coverage when they also may be eligible for Medicare.

CMS has set April 1, 2009, as the beginning of the testing period. To ensure we are able to properly submit test data to CMS, we must have collected Social Security Numbers as required by this regulation. The penalty for failure to submit the required data will be $1,000 per member per day.

Because of this stiff fine, your help is essential in making sure we are able to meet this new requirement. Together, we can make sure we keep plan costs stable by ensuring all numbers for currently enrolled subscribers and their spouses or domestic partners and certain dependents are collected.

Updated enrollment forms

We have updated our enrollment forms to include a space for Social Security Numbers for new or renewing groups. You can also contact your ODS Marketing Representative or Account Executive for printed or electronic copies.

For more information

If you have any questions or concerns about this requirement, please contact your ODS Marketing Representative or Account Executive. We will be in touch soon with more information about our implementation plan.

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