Coverage and coordination of benefits information for Medicare Parts A and B General Information There are a few ways people become eligible for Medicare. The most common are: • Age • Disability • End Stage Renal Disease (ESRD) It is the employer and/or the employee’s responsibility to advise Dean Health Plan of any eligibility and/or enrollment in Medicare Part A or Part B, regardless of the reason for that enrollment. Failure to do so may cause delays or incorrect processing of claims. Enrollment Enrollment in a Dean Health Plan group policy is based on an employee’s current employment status at the time he or she qualifies to enroll (actively at work, retired, COBRA or severance). The Social Security Administration (SSA) and Dean Health Plan follow the same guidelines to determine employees’ Medicare eligibility. Use the Medicare summary charts to identify when employees are “working” and “not working” to determine if enrollment in Part B is advisable to reduce the employee’s out-of-pocket expenses. The only exception to this rule is if the employee is covered under Medicare’s ESRD program. An employee cannot be forced to enroll in any part of Medicare. However, per an employer's Member Certificate, Dean Health Plan will pay as if the employee was enrolled, which means the employee will incur out-of-pocket expenses for amounts that Medicare would likely have paid. If an employee is getting ready to enroll in any non-actively-working segment, such as retiree, COBRA, continuation, long term disability (LTD), severance or other “non-working” status while covered by the employer’s plan, remind the employee to review his or her responsibility to enroll in Medicare, if eligible. Employees may check on their Medicare eligibility by contacting the local SSA office or by calling our Medicare Coordination of Benefits (COB) Analyst for assistance. The contact numbers are in the Medicare section of this document. If the employee contacts the SSA office, he or she should be prepared to give as much detail as possible concerning his or her planned retirement or termination from work. This may include the employer size, his or her work status and the work status of his or her spouse. Any paperwork the employer can furnish indicating the member’s retirement/termination may prevent delayed or denied medical claims. Regardless of circumstances, it is ultimately the employer and/or the employee’s responsibility to ensure Dean Health Plan is made aware of Medicare eligibility and enrollment, for any reason. If the employer or employee is unsure when Medicare enrollment is advisable to avoid out-of-pocket expenses, please call the Medicare COB Analyst at the number indicated at the end of this section. Employer Group Size Employer group size is determined by the number of employees on the payroll records for the prior IRS calendar year as indicated in the Medicare Secondary Payer Manual. Dean Health Plan will be the primary payer only when required by federal regulations. The “working” and “not working” charts below display the criteria that SSA uses when determining beneficiary eligibility and whether Dean Health Plan will be the primary payer before Medicare. It is very important for coordination purposes that the employer report accurate employee numbers to Dean Health Plan on the Group Information Form sent each year for renewal, or the Employer Application for Group Coverage Form when initially enrolling with Dean Health Plan. Medicare Secondary Payer Manual, Chapter 2 indicates: 10.3 - The 20-or-More Employees Requirement: This rule applies if an employer has 20 or more full time and/or part-time employees for each working day in each of 20 or more calendar weeks in the current or preceding year. 30.2 - The 100-or-More Employees Requirement: This rule applies to employers that employed 100 or more full-time and/or part-time employees on 50 percent or more of its business days during the previous calendar year. Medicare is secondary for all employees enrolled in a multi-employer plan, such as a union plan which covers employees of some small employers as well as employees of at least one employer that meets the 100-or-more employee requirement, including those that work for small employers. There is an exception to the working aged provision, as it does not apply to the payment order determination if the employee is enrolled in Medicare due to a disability. An employer will be considered to employ 100 or more employees on a particular day if the employer has at least 100 full-time or part-time employees on his/her employment payrolls on that day, regardless of the number of employees who work or who are expected to report for work on that day. Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 established mandatory reporting requirements for group health plans. All group health plans, including Dean Health Plan, are required to comply. Each December, a form will be sent to you requesting information about your group size for the current year. Dean Health Plan is required to report this information to CMS so it is essential that the form is completed accurately and promptly returned. It is the employer's responsibility to notify Dean Health Plan immediately if the group size changes from fewer than 20 to 20 or more employees for 20 weeks or more (the weeks do not have to be consecutive). Each May (which is 20 weeks into the year) a reminder notice is sent to Groups that reported fewer than 20 employees in the previous year, to help groups remember to report a change to 20 or more employees. The reminder notice must be returned if the Group has increased the number of employees to 20 or more for 20 or more weeks (the weeks do not have to be consecutive) since January 1 of the current year. Medicare Questionnaire Each month, Dean Health Plan sends a Medicare Questionnaire to employees who are about to reach the age of 65. This is sent to members approximately 60 days prior to the member’s birth date. Each letter is specific to the employee's current work status and is personally addressed to that individual. If no response is received within 30 days, a second request is sent. If no response is received from the second request, we will complete a review using the Medicare Data Match through the Centers for Medicare and Medicaid Services (CMS). We will update its system based on the information obtained through CMS. In cases where information is not provided, the information from Medicare will take priority. By State law, if we have on record that you employ 19 or fewer individuals, you will also receive a copy of this questionnaire. Prior to a Medicare Demand Letter, the Coordination of Benefits & Recovery Center (CRC) will send a Primary Payment Notice (PPN) to both the impacted employer and the insurer/TPA (Third Party Payer). The PPN is a notice to the employer to advise them that the Centers for Medicare & Medicaid Services (CMS) has identified instances where Medicare may have mistakenly made a primary payment when other primary insurance exists. Enclosed with this notice is a PPN worksheet that lists Medicare beneficiaries and corresponding coverage dates. The notice requests the employer to review the worksheet, make corrections and additions as necessary, and mail or fax the completed worksheet to the CRC. Medicare Demand Letters - Requests for a Refund These requests are sent to the last employer known to Medicare. These requests are sent as a result of a possible debt that may be owed to Medicare because it may have mistakenly paid primary for medical claims Dean Health Plan should have paid. These requests are extremely time sensitive and require immediate action by the employer. If the response to these requests is not received by Medicare within 60 days from the date of the initial request, interest is added and is accrued monthly. Medicare does not make allowances for postal service delays. If you receive a Medicare demand letter and the individual concerned was insured with Dean Health Plan, please contact the Dean Health Plan Medicare COB Analyst to ensure Dean Health Plan has received a copy. Dean Health Plan will review all claims sent, make payments as necessary and ensure the employer receives a copy of the final disposition of that request. If the employee is insured by Dean Health Plan, it is your responsibility to ensure that we are advised of all such letters. If you have any questions about these requests, please call our Medicare COB Analyst at 608-827-4189. After Medicare completes its review, it will respond with a letter indicating no further payment is required and the “case is closed,” or it will request additional information or payment. Failure to comply with the federal laws concerning these refund requests can make the Employer Group responsible for the amount due. In addition, if there is any delay determined as “inappropriate” by Dean Health Plan, the Employer Group may be liable for any interest accrued from that delay. Failure to Notify Dean Health Plan of Medicare Eligibility Resulting in Claim Reversals and Premium Changes If the employee/dependent fails to inform the employer or Dean Health Plan that they are eligible for Medicare, the situation will be reviewed and action may be taken. We have the legal right to recover funds paid incorrectly when information of this type is discovered. • The specific employee will be notified by letter of this change to the primary payer of the medical claims and given the reasons and dates in question. • The employee/dependent will also be referred to the nearest SSA office to consult about possible options available. Medicare premiums will only apply if Medicare is the primary payer regardless if the member is enrolled in Medicare Part B. Medicare Eligibility Summary Charts Employee Who is Currently Working NUMBER OF EMPLOYEES ENROLLMENT IN MEDICARE A & B PRIMARY PAYER SECONDARY PAYER RATING STRUCTURE 2-19 Enrollment is strongly recommended for employee/dependents to ensure employee has the least out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 2-19 & Medicare Disabled Enrollment is strongly recommended for employee/dependents to ensure employee has the least out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 20-99 Not mandatory, may defer for employee/dependents Dean Health Plan Medicare Full 20-99 & Medicare Disabled Enrollment is strongly recommended for employee/dependents to ensure employee has the least out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 100+ Not mandatory, may defer for employee/dependents regardless of age or Medicare disability Dean Health Plan Medicare Full Employee Who is Not Currently Working NUMBER OF EMPLOYEES ENROLLMENT IN MEDICARE A & B PRIMARY CARRIER SECONDARY CARRIER RATING STRUCTURE 2-19 Enrollment is strongly recommended for employee/dependents to ensure employee has the lowest out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 2-19 & Medicare Disabled Enrollment is strongly recommended for employee/dependents to ensure employee has the lowest out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 20-99 Enrollment is strongly recommended for employee/dependents to ensure employee has the lowest out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 20-99 & Medicare Disabled Enrollment is strongly recommended for employee/dependents to ensure employee has the lowest out-of-pocket amounts Medicare Dean Health Plan Medicare Rate 100+ Enrollment is strongly recommended for employee/dependents regardless of age or Medicare disability to ensure employee has the lowest out-of-pocket amounts Medicare Dean Health Plan Medicare Rate Due to ACA regulations Small Employer Groups do not receive rate adjustments for Medicare primary members. Coverage for individuals with End-Stage Renal Disease (ESRD) does not vary with employer group size or active work status of the individual or spouse. The employee should contact the SSA for more information. These guidelines do not reflect all the possible criteria affecting the primary payer determination. For further details, please contact the Social Security Administration. Medicare Contact Information Dean Health Plan Medicare Department Contact our Medicare Coordination of Benefits Analyst for questions on Medicare eligibility, premiums and coordination of benefits. 608-827-4189 – Phone Social Security Administration 800-772-1213 – Toll Free ssa.gov Medicare 800-633-4227 – Toll Free medicare.gov Medicare Coordination of Benefits Center 800-999-1118 – Toll Free State of Wisconsin Office of the Commissioner of Insurance 800-236-8517 – Toll Free oci.wi.gov U.S. Department of Labor 202-219-8776 – Phone dol.gov Retirees If the employer does not offer retiree coverage, retiring employees may be offered COBRA/State Continuation. Refer to COBRA for additional information. Please Note: An employee is eligible for COBRA /State Continuation if he or she is Medicare-eligible. A second option is enrolling the employee in a group retiree segment through Dean Health Plan, provided one has been previously approved for your group. Retiree Segment Requirements and Set Up The employer’s retiree policy must address and meet the following guidelines: A formal, written policy outlining retiree benefits offered. Example: Insured employees who have at least 25 years of service and who are age 55 are eligible for retiree benefits. The definition must apply for all eligible insured employees within Dean Health Plan's service area. The definition must state how long a retiree can remain covered under the retiree segment. This is usually limited to age 65 or eligibility for Medicare. The eligibility requirement should contain clarification on coverage for spouses/dependents. Example: The spouse and dependents can remain covered under the retiree segment as long as they were insured prior to the employee’s retirement. In addition, the policy should clarify what happens to coverage of the spouse/dependents should the retiree pass away. If the employer offers health plans from other carriers, they must agree to allow the retiree coverage. If the other carriers do not agree to offer the retiree coverage or cancel the retiree coverage at a later date, you must notify Dean Health Plan. The employer's premium contribution to the retiree’s coverage must be at least 25 percent of the single premium across all tiers and must be the same for all insured. This may be achieved through pension benefits or accrued sick and vacation time the company allows to be used for health insurance premium payments. The options for coverage changes at annual enrollment time must be noted. Example: Can the retirees switch between health plans at annual enrollment or are they required to remain on the plan chosen at retirement indefinitely? Medicare – If Dean Health Plan approves a policy that covers retirees who are Medicare-eligible, such retirees are required to enroll in both Medicare Parts A and B. Dean Health Plan will pay secondary to Medicare whether or not the retiree elects Parts A and B. Special Enrollments – If a retiree acquires a new dependent as a result of marriage, birth, adoption or placement for adoption, the retiree may be able to enroll himself or his qualified dependents in the plan provided that we receive an application for enrollment within 31 days after the date of the event. If the retiree waives Dean Health Plan retiree or dependent coverage when initially eligible for coverage under the retiree plan, one subsequent enrollment into the retiree plan will be allowed, but only if other group coverage (excluding dual choice coverage) is involuntarily lost and Dean Health Plan receives an application for enrollment within 31 days following the date coverage was lost. Standard Retiree Participation Levels and Ongoing Monitoring – Maximum retiree participation levels have been established to control the amount of risk presented by retiree policies. For groups with two to 25 total employees, the standard maximum participation level for retirees may not exceed 10 percent of the total group enrollment with us. For groups with 26 or more employees the standard maximum participation level for Dean Health Plan retirees may not exceed 25 percent of the total group enrollment with Dean Health Plan. Please Note: A group may elect to freeze retiree enrollment at any time to prevent retiree participation from growing further. In any case, rates would be adjusted to appropriately reflect the risk presented by the retiree population if it exceeds 10 percent and retirees may be rated separately if appropriate based on the below guidelines. Enrolling in a Retiree Segment An Employee Application for Group Coverage Form must be completed by the employee upon retirement. The employee will check “transfer to retiree segment” under “Reasons for Application” and should indicate effective date of change. The employee should also note in Section D of the application if he or she has enrolled in Medicare. Because Medicare is the primary payer for members on the retiree segment, all retirees and dependents who qualify for Medicare are strongly advised to enroll in both Part A & B because Dean Health Plan will pay claims as if they are enrolled. The Employee Application for Group Coverage Form should be received by Dean Health Plan within 31 days of the retirement date. Retirees will be noted on the billing statement under a separate group number (similar to COBRA enrollees).