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CMS Data Match

History and Applicability

This reporting was started to provide CMS information about Medicare beneficiaries' group health plan (GHP) coverage. The law requires the Internal Revenue Service (IRS), the Social Security Administration (SSA), and CMS to share information that each agency has about whether Medicare beneficiaries or their spouses are working.


The purpose of the Data Match is to identify situations where another payer may be primary to Medicare.


Who does the reporting requirement apply to?

The data match requirement is an obligation of the employer/plan. Employers that receive a questionnaire from CMS should take the time to complete and the return the document.


Meritain Health will not complete or submit the report on behalf of the plan, but we will provide the information the plan/employer needs, upon request, to compete and file the report with CMS.


What must be reported?

A questionnaire must be completed containing information to identify situations where another payer may be primary to Medicare. Employers will report on workers who are entitled to Medicare or married to an individual who is a Medicare beneficiary.


How often is reporting required?

CMS contacts employers regarding reporting and employers must respond within 30 days of the initial inquiry, unless an extension has been requested and approved.


To request a 30 day extension, employers may contact CMS's Recovery Center by phone at 1-800-999-1118.


Requests for extensions beyond 60 days (the original 30 days and one 30-day extension) generally are not granted to any employer if reporting on fewer than 150 workers and any requests for extensions beyond the 60-day period must be submitted by letter detailing the reasons and sent to:


IRS/SSA/CMS Data Match Project

PO Box 660

New York, NY 10274-0660



The penalty for non-compliance for CMS Data Match is $1,000 per member, per day that the information is not reported to CMS.


This means for a group that is missing Social Security numbers on ten individuals, the penalty would be $10,000 per day, and if it takes 30 days to gather the information, the total penalty that could be assessed would be $300,000.


This content is being provided as an informational tool. It is believed to be accurate at the time of posting and is subject to change. 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 information, Meritain Health is not exercising discretionary authority or assuming a plan fiduciary role, nor is Meritain Health providing legal advice.