In early February, the American Insurance Association (AIA), a group of representatives of the property-causality and self-insurance industries, sent a letter to the Secretary of the Department of Health and Human Services, Kathleen Sebelius, requesting her to delay the April 1, 2010 implementation of the Medicare Secondary Payer (MSP) mandatory reporting requirements. AIA argues that a “more realistic” implementation date is appropriate and imperative because the Centers for Medicare and Medicaid Services (CMS) has not yet provided appropriate reporting guidance to insurers and self-insurers. AIA claims that the test period for the electronic reporting system was inadequate to ensure that the system is fully operational prior to the implementation date. Additionally, AIA states that the industry has serious concerns with the mandatory requirement to submit certain types of data (i.e., Social Security numbers), especially when it appears that CMS is not properly using the appropriate technology to ensure the privacy of personally identifiable information. Finally, AIA argues that the MSP Act’s penalty provision of $1,000 per day, per claim, is excessive and, at the very least, should not be assessed on the first report submitted by any entity.