2010.3.30 - Section 111 DOES NOT apply to me

From: Clay Shentrup <clay@zendesk.com>
Date: Tue, Mar 30, 2010 at 12:06 PM
Subject: Re: question
To: "Young, Dana" <Dana.Young@trinet.com>

Dana,

I have confirmed that Section 111 of S. 2499 does not apply to me, as I am under 45 and am not known to be entitled to Medicare. Here's a release directly from the Centers for Medicare and Medicaid Services, which specifically states the criteria for reporting -- which is reflects exactly what I was told by an agent named Victoria at Blue Shield.

For purposes of Section 111 reporting, active covered individuals are:

All individuals covered in a GHP age 45 through age 64 who have coverage based on their own or a family member¿s current employment status.

All individuals covered in a GHP age 65 and older who have coverage based upon their own or a spouse's current employment status.

All individuals covered in a GHP who have been receiving kidney dialysis or who have received a kidney transplant, regardless of their own or a family member's current employment status.

All individuals covered in a GHP who are under age 45, are known to be entitled to Medicare [which I, Clay Shentrup, am definitely not], and have coverage in the plan based on their own or a family member¿s current employment status. When reporting on these under age 45 individuals, you must submit their Medicare Health Insurance Claim Number (HICN).

-- Here's a PDF of this, direct from cms.hhs.gov
http://www.cms.hhs.gov/MandatoryInsRep/Downloads/GHPDataElements.pdf

Furthermore, the letter I received states that Blue Shield has instructed you that they require the SSN. This information is incorrect or out of date. As I said in a previous email, I have exhaustively checked with Blue Shield about this, and they have even replaced my SSN with my "J number". Here's what I said in a previous email.

Victoria (ext 6145) at Blue Shield, says that they can and often do use alternate numbers in place of SSN's. She said there is actually a recent law (I don't know the exact name of the law) that stipulates subscribers do not have to use their SSN. She is going to see whether they can just manually change it without requiring a push from Trinet. But if I push from Trinet is necessary, it sounds like that is perfectly acceptable to them.

I have spent a great deal of time on this issue for the past 3 months, and I believe I've conclusively shown that the cited law does not apply to me, by citing an official government document which clearly states the applicable criteria. Therefore I believe it is not mutually exclusive that my coverage continue and Trinet removes my SSN from all health insurance company records via a record update. I would like to have this resolved by week's end if at all possible. I feel I have waited long enough.

Thanks for your time and considerable help in all of this.

Regards,
Clay Shentrup