Section title: Requests for Interpretation
RFI #
1890
834 Medicare Advantage
Description

I would like an interpretation of the rule for INS08 when enrolling Medicare Advantage members.

To follow Medicare ‘billing’ guidelines if an enrollee has ESRD it must be reported; however, the only place to report this in the 834 is INS06-2. This then makes INS06-1 required where a value for Medicare Status is reported. Medicare Advantage employer groups want to report RT-Retired in INS08, but because INS06-1 has a Medicare Status value, the compliance checkers are stopping the file for having a value other then AC or TE in INS08.

Because Medicare Advantage is not a Federally Administered program (non-employment based), can a value other than AC or TE be reported in INS08 when INS06-1 is reported so INS06-2 can be reported for ESRD?

RFI Response

INS06 (Medicare Status Code) identifies when there is Medicare coverage and an associated reason for Medicare eligibility. Medicare coverage can be through non-employment or employment sponsored offerings, but is still Medicare coverage and INS06 would be reported.

When the Medicare coverage, e.g. Medicare Advantage (Part C) or Drug (Part D) is offered through an employment situation, INS08 can be other than “AC” or “TE”.

DOCUMENT ID
005010X220