United States: The PAID Act Is Now Active, Allowing Access To Enrollment Information For Medicare Parts C And D

According to an announcement issued by the Centers for Medicare & Medicaid Services (CMS) on December 13, the Provide Accurate Information Directly (PAID) Act was implemented and became live effective December 11, 2021.

Up to this point, when claims were reported to CMS pursuant to Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA), a query would only identify a beneficiary's enrollment status under traditional Medicare Part A (Hospital Insurance) and Part B (Outpatient Insurance).  CMS uses this information to identify conditional payments made by Medicare related to the reported claim.  However, when a beneficiary used Medicare Part C (Medicare Advantage Plan) or Part D (Prescription Drug Coverage), these payments would not be reflected in the Medicare conditional payment search.  According to information published by CMS in June 2021, it was estimated that 1 out of 3 beneficiaries had a Part C plan, and 9 out of 10 had some form of Part D coverage.  Because there was no reliable way to identify a beneficiary's coverage under Medicare Parts C and D, stakeholders in the Medicare Secondary Payer industry supported the PAID Act, which was passed by Congress and enacted on December 11, 2020.

Under the PAID Act, CMS will provide Non-Group Health Plans with up to 3 years of enrollment data for beneficiaries covered under both Part C and Part D plans.  This data will be supplied under Section 111 reporting, as part of the Query Response File.  The intention of the PAID Act is to help carriers and CMS better coordinate the payment of benefits.

Practice Tip

When verifying Medicare conditional payments, be aware of treatment paid by traditional Medicare, Medicare Advantage Plans, and Medicare Prescription Drug Plans.  Beneficiaries may have coverage with several different carriers, which is subject to change during the annual open enrollment periods.

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