The Centers for Medicare and Medicaid Services (CMS) routinely contacts employers as part of the Data Match Project. The IRS, SSA, and CMS work together to ensure that employer group health plans pay primary to Medicare when appropriate.

If your organization has 20 or more employees, your group health plan is the primary payer of benefits, and Medicare is secondary, for active employees and their spouses. If claims need to be re-adjudicated, the CMS will contact your group health plan carrier. You are only responsible for providing the Data Match information to the CMS.

You may receive a letter from the CMS asking you to complete a Data Match questionnaire on the CMS website. Once you register and log on, you will complete information about your employer size, the group health plan, and the coverage and employment status of specific employees. These employees, and/or their spouses, would have been eligible for Medicare coverage during the years under review.

Please note that several clients recently received CMS letters indicating that they had not responded to an initial notice sent early in 2016 and they were at risk of a penalty assessment. As long as you respond timely and accurately to your most recent notice, there will not be a penalty assessment.

If you need assistance completing the Data Match questionnaire, please contact Lynne Pettey ( or Adina Cohen ( in Keller’s legislative compliance department.