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Medicare Secondary Payer (MSP) Employer Size

Independence Blue Cross (Independence) and its affiliates are required to collect information from you regarding your employer size in order to ensure proper coordination of benefits and reporting under the Medicare Secondary Payer (MSP) laws.

The Centers for Medicare & Medicaid Services (CMS) uses MSP information to determine whether Independence or Medicare is the primary payer of claims for your Medicare-eligible employees.

It is in each group’s interest to provide accurate employer size information in a timely manner in order to comply with MSP regulations, reduce coordination of benefits costs, and reduce the number of demand letters received and/or other potential enforcement or recovery actions by the government.

What you need to do:

Current Year MSP Employer Size Survey

• Please submit the MSP Employer Size Survey when you meet any of the MSP employer size thresholds during the current year.
• To ensure Independence is collecting current year MSP employer size determinations, this survey will be available, and must be completed, between 5/1-12/31 of the current year.
• Since employer size thresholds may be met at different times during the year, it is the employer's responsibility to monitor employer size throughout the year and promptly inform Independence when a new size designation is met.
• Please be aware that it is possible to meet two employer size thresholds during the current year, and both must be reported. If you meet a new MSP employer size threshold after you have completed the survey, or you failed to report meeting an employer size threshold earlier in the current year, please resubmit the survey with the updated information prior to 12/31 of the current year.

Please note: To complete the current year survey, you will need your Company ID (CID) Number, which was provided to you on the MSP survey notification letter that you received from Independence or you can ask your Independence Account Executive or Broker.

Retroactive MSP Employer Size Form

If you miss the 12/31 survey deadline, or you need to correct MSP employer size submissions from prior years, please complete the Retroactive MSP Employer Size Form and submit to your assigned Independence account executive. If you don’t know who your account executive is, call 1-800-ASK-BLUE.

Please note: To complete Retroactive MSP Employer Size Form, you will need your Company ID (CID) Number, which was provided to you on the MSP survey notification letter that you received from Independence or you can ask your Independence Account Executive or Broker.

Disclaimer: The survey and form are meant to assist you in making employer size determinations. It is not intended to serve as legal advice. It is your company’s responsibility to timely and accurately report employer size consistent with the MSP rules. If you have any questions concerning application of the employer size rules under the MSP laws, or your company’s legal obligations under the MSP laws, you should contact your legal advisor. Additional information is available in the MSP laws and regulations, and at CMS.gov.