The Centers for Medicare and Medicaid Services (CMS) have modified the definition of an HRA for reporting purposes. CMS has removed the distinction between a free-standing HRA and an embedded HRA meaning all HRAs are reportable if they meet the $1,000.00 value threshold.
The Medicare Secondary Payer Mandatory Reporting User Guide for group health plans has been updated to address the required reporting of "linked" HRA coverage and other changes, such as the obligation of responsible reporting entities to provide information to CMS when group health plans are or have been primary to Medicare.
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