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Collect and Report Retirement Dates on Medicare Claims

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Collect and Report Retirement Dates on Medicare Claims

A long-standing policy from the CMS requires providers to collect retirement dates during their MSP screening process and to report these dates on Medicare claims. The CMS instructs its Medicare contractors, while conducting MSP Hospital Reviews (also known as MSP Hospital Audits), to validate that hospitals are reporting retirement dates on claims when such dates have been collected during the MSP screening process. Because retirement constitutes a change in a beneficiary’s MSP status, retirement information, just like any other event that may cause a beneficiary’s or his/her spouse’s active employment to terminate, should be reported to the BCRC. As you will review below, providers can do this by reporting this information on your Medicare claims so that we can send that information to the BCRC.  Refer to Correct a Beneficiary’s MSP Record.

Retirement dates can be used, when necessary, to update certain GHP-related MSP records on the CWF, e.g., Working Aged with EGHP records and Disabled with LGHP records, and may prevent the provider from receiving unnecessary MSP claim rejections. Although it is possible that certain claims will process for payment without the retirement date information (because there is no current GHP-related MSP record on the CWF that needs to be updated), providers should still collect and report this information on Medicare claims.

Under the Medicare provider agreement, all Medicare providers are required to identify and bill payers that are primary to Medicare. Knowing whether or not a Medicare beneficiary, his/her spouse and/or family member (as applicable) is still working or is retired is an important part of being able to determine which payer (Medicare or the GHP) is the appropriate primary payer for the beneficiary’s service(s). To make this determination, providers conduct an MSP screening process during which the provider asks the beneficiary (or his/her representative) questions concerning the beneficiary’s most current MSP status. Part of this process is collecting accurate retirement dates. To view the types of admission questions providers should ask during the MSP screening process, refer to the CMS IOM Publication 100-05, Medicare Secondary Payer Manual, Chapter 3, Section 20.2.1 - Admission Questions to Ask Medicare Beneficiaries.

This set of questions is also known as the MSP questionnaire.

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Recording Retirement Dates in the Provider’s Records

When completing the MSP questionnaire (or provider’s own similar form) with the beneficiary, the provider should document the retirement date(s) as applicable. Retirement date fields should not be left blank unless the beneficiary and/or spouse, as applicable, never worked which should also be documented if that is the case. Leaving such fields blank may make it appear, to anyone reviewing such records, as though the provider did not ask for the information.

The provider is permitted to assist the beneficiary, when necessary, in recalling his/her most accurate retirement date. If the beneficiary, and/or spouse, as applicable, cannot recall his/her specific date(s) of retirement, the CMS has a policy that assists the provider in selecting appropriate retirement date(s) to record and report. This policy was intended for hospitals, however, we suggest that all providers become familiar with and use this policy in the same circumstances. This policy can be found in the CMS IOM Publication 100-05, Medicare Secondary Payer Manual, Chapter 3, Section 20.1, Number 4 - Policy for Medicare Secondary Payer Retirement Dates.

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Reporting Retirement Dates on Claims

Retirement dates are reported on the CMS-1450 claim form in FLs 31-34 or the equivalent field 2300HI (BH) of the 837I with OC 18 and date of the beneficiary’s retirement and OC 19 and date of the spouse’s retirement. In most cases, unless there is a conflict, Medicare can send the retirement date information that you submit on your claims to the BCRC to update any applicable GHP MSP record in CWF.

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Revised 10/26/2023