In March 2017, the HHS Secretary and CMS Administrator under the Trump Administration released a letter to state governors noting the new Administration’s plan to conduct a “full review of managed care regulations to prioritize beneficiary outcomes and state priorities.” 5 CMS then released an Informational Bulletin in June 2017, indicating it would use “enforcement discretion” to work with states on achieving compliance with the 2016 final rule, except for specific areas that “have significant federal fiscal implications.” 6 CMS’s stated goals in releasing the November 2018 Notice of Proposed Rulemaking (NPRM) to revise the 2016 final rule were to streamline the managed care regulatory framework reduce state and federal administrative burden support state flexibility and promote transparency, flexibility, and innovation in care delivery. 3 CMS’s major goals in issuing the 2016 final rule were to align Medicaid managed care requirements with other major health coverage programs where appropriate enhance the beneficiary experience of care and strengthen beneficiary protections strengthen actuarial soundness payment provisions and program integrity and promote quality of care. final rule represented a major revision and modernization of federal regulations in this area, which had not been updated since 2002. 1 CMS last revised these regulations in 2016 (“the 2016 final rule”) under the Obama Administration. The BCRC EDI Department’s contact number is 1-64.On November 13, 2020, the Centers for Medicare and Medicaid Services (CMS) finalized changes to the Medicaid managed care regulations. To enroll in the COBA program, contact the BCRC’s Electronic Data Interchange (EDI) Department to discuss COBA service options which will be customized to your organization. The Drug Coverage Record Layout may also be downloaded from the COBA File Formats and Connectivity page. Trading partners that provide drug coverage that pays supplemental to Medicare Part D coverage have the option of reporting this eligibility data to CMS via the COBA E-02 Eligibility File. For those beneficiaries listed on the eligibility file, the BCRC will transfer claims to trading partners in the HIPAA American National Standard Institute (ANSI) Accredited Standard Committee (ASC)-X12 837 COB (versions 5010AA2) and National Council for Prescription Drug Programs (NCPDP) version D.0 batch standard 1.2 formats. Please visit the COBA File Formats and Connectivity page for additional information. Trading partners generate an eligibility file to the BCRC using the COBA Eligibility (E-01) Record Layout format. How a Coordination of Benefits Agreement Works The Downloads section, near the bottom of the page, contains the COBA Implementation User Guide, the standard COBA Agreement, the COBA Attachment, and other related documents. COBA trading partners are apprised of situations where their eligibility information matches CMS eligibility data as well as when their submitted information does not result in a match. COBAs permit other insurers and benefit programs (also known as trading partners) to send eligibility information to CMS and receive Medicare claims data for processing supplemental insurance benefits from CMS’ national crossover contractor, the Benefits Coordination & Recovery Center (BCRC). The BCRC houses COBA trading partner’s eligibility information for crossover purposes only in those instances where the information successfully matches with the in-file CMS entitlement information. CMS developed a model national contract, called the Coordination of Benefits Agreement (COBA), which standardizes the way that eligibility and Medicare claims payment information within a claims crossover context is exchanged.
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