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Home > Resources > Compliance Resources > Compliance Quarterly > July 2009 Compliance Quarterly > Update: Medicare, Medicaid and SCHIP Extension Act of 2007

Medicare, Medicaid and SCHIP Extension Act of 2007

Update on Meritain Health's Efforts Toward Compliance with Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007

Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (Section 111) adds mandatory reporting requirements related to Medicare beneficiaries who have coverage under group health plan (GHP) arrangements. It also applies to Medicare beneficiaries who receive settlements, judgments, awards or other payment from liability insurance (including self-insurance), no-fault insurance and workers' compensation.

Implementation dates are January 1, 2009 for GHP arrangement information and July 1, 2009 for information concerning liability insurance, no-fault insurance and workers' compensation. For more information, please refer to the previous article regarding this matter.

Who is eligible for coverage under Medicare?

Medicare is a health insurance program for:

  • People age 65 or older.
  • People under age 65 with certain disabilities.
  • People of all ages with End-Stage Renal Disease (permanent kidney failure requiring dialysis or a kidney transplant).

Some people who are covered by Medicare also have group health coverage. Often, employer-provided group health coverage must pay before Medicare does. In that case, Medicare is the secondary payer.

Why Section 111 was created?

The primary reason for creating Section 111 is that Medicare has determined that a more robust data exchange with private payors will better ensure that Medicare benefits are not paid when Medicare is a secondary payer to a GHP arrangement.

What does this mean to Meritain Health and our clients?

  • Meritain Health will facilitate the collection of all data necessary for compliance compliant.
  • Meritain Health is producing reports that highlight any missing system data that is necessary for compliance. Meritain Health is sending these reports to clients, along with instructions regarding what is needed and how to fill in the missing data.
  • Meritain Health will provide clients with an outline of responsibilities and deadlines.
  • Meritain Health holds the responsibility for compliance. Once the data is collected, Meritain Health will ensure that all information is properly transmitted to the Centers for Medicare & Medicaid (CMS).


Compliance Quarterly is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.