e-NMSN—Answers to Employers’ Questions (Aug. 2, 2022)
The HHS Office of Child Support Enforcement (OCSE) has posted frequently asked questions about e-NMSN—a free, voluntary system for the electronic exchange of National Medical Support Notices (NMSNs) between state child support agencies and employers, plan administrators, TPAs, and unions. As background, an NMSN is a standardized medical child support order that is used by state child support enforcement agencies to obtain group health coverage for children. A properly completed NMSN is considered a Qualified Medical Child Support Order (QMCSO) for ERISA purposes.
The FAQs note that the e-NMSN process, which went live in February 2022, allows children’s health coverage to begin sooner; is more accurate and reliable than a paper process; and saves time, money, and resources. Under e-NMSN, OCSE receives NMSN files from child support agencies and, within one day, delivers the files to secure servers designated by participating employers. (e-NMSN requires either a Secure File Transfer Protocol (SFTP) server or a File Transfer Protocol Secure (FTPS) server.) After the employer and plan administrator (if different from the employer) complete the required information, e-NMSN facilitates the transfer of the files back to the child support agency. Employers, plan administrators, and TPAs in participating states may register for e-NMSN on the OCSE website.
EBIA Comment: Because e-NMSN is new and participation is voluntary, not all states have implemented the process. Regardless of the mode of transmission, employers and group health plan administrators that receive NMSNs must timely process them in accordance with DOL and HHS regulations and the NMSN instructions. For more information, see EBIA’s Group Health Plan Mandates manual at Sections V.A (“What Are QMCSOs and Who Must Comply?”) and V.H (“National Medical Support Notices (NMSNs)”).
Contributing Editors: EBIA Staff.