IBC: Information Required by CMS to Accurately

Independence Blue Cross (IBC) is required by the Centers for Medicare & Medicaid Services (CMS) to collect information regarding the total number of employees for each of their customers. CMS uses the total number of employees, also referred to as employer size or employee count, to determine whether a private insurer or Medicare is the primary payer for Medicare-eligible employees’ and Medicare-eligible dependents’ claims. As a result, IBC will need accurate and up-to-date information to ensure that claims are processed according to Medicare Secondary Payer (MSP) regulations.

To gather this information, IBC recently sent letters to customers with 1 – 300 employees asking them to complete an MSP Data Collection Worksheet.   Failure to return the worksheet may result in the imposition of fines or penalties on the customer or IBC.

Due to a system error, this mailing was also issued incorrectly to groups who have terminated their medical or dental-only plans with either Independence Blue Cross or Independence Administrators.

Please note that only active Independence customers must return the MSP Data Collection Worksheet and to follow the instructions provided on the form. Clients that are no longer active Independence customers can disregard the letter.

Independence Blue Cross will send up to three letters to employers requesting this information.


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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.