Question on Sellers of Prepaid Cards - For some reason we never reported our convenience stores, pharmacies, and other retailers who sell Visa cards, gift cards etc. In rereading the MLR instructions I now wonder if we should have been reporting. When we open accounts for these entities we ask if they will sell more than $XX to any one customer in any one day and if they say no – then we didn’t track. But apparently, if they are sold before obtaining ID we need to track and report for MLR. Or am I reading it wrong.
Sellers of Prepaid Access:
A seller of prepaid access is any person or organization that receives funds or the value of funds in exchange for an initial loading or subsequent loading of value onto prepaid access devices.
Such a person or organization, including a retailer such as a pharmacy, convenience store, supermarket, or discount store, is not considered a “seller of prepaid access†if:
a) it sells prepaid access under a prepaid program that can be used only after the user’s identification needs to be verified; and
b) it has policies and procedures in place that are reasonably adapted to prevent the sale of more than $10,000 of any type of prepaid access to any one person on any one day.
Such a person is considered a “seller of prepaid access†if it either sells prepaid access that can be used before the user’s identification needs to be verified or does not have policies and procedures, and does engage in sales, described in item (b) above.