Monday, March 16, 2020

Historic Rules on Health Data: Highlights of Two Provisions that affect Dually Eligible Individuals


On March 9, CMS issued the Interoperability and Patient Access final rule (CMS-9115-F). The final rule establishes policies that break down barriers in the nation’s health system to enable better patient access to their health information, improve interoperability and unleash innovation, while reducing burden on payers and providers.  
Two provisions will specifically affect dually eligible individuals. The first requires daily state-CMS exchange of data to identify who is enrolled in Medicare, and which party is liable for paying each beneficiary’s Parts A and B premiums (commonly referred to as “buy-in” files). The second requires daily state submission of Medicare Modernization Act (MMA) files, which identify all full-benefit and partial-benefit dually eligible beneficiaries. States and CMS currently exchange these data as infrequently as monthly in many states. Moving to daily data exchange will expedite enrollment status changes, improve customer experiences, and reduce the volume of payment inaccuracies and recoupments. Improving the accuracy and timeliness of data on dual eligibility status is an important step in improving how Medicare and Medicaid work together for beneficiaries, providers, and payers. Both provisions require daily exchange by April 1, 2022.   
CMS will provide technical assistance to the 35 states that currently submit monthly/weekly to shift to daily submission.  Please click here for more information on the MMA file and how to contact us for assistance. For technical support on buy-in file exchange, state staff should contact the CMS Office of Information Technology at MEPBSEDBSSStaff@cms.hhs.gov (and copy DPBCStateBuy-In@cms.hhs.gov). 
The final rule is available on the CMS website. For the provisions specific to dually eligible individuals, please see Section VII (Improving the Medicare-Medicaid Dually Eligible Experience by Increasing the Frequency of Federal-State Data Exchanges) and final changes to regulatory text in Parts 406, 407, and 423.

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