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IS THE INFAMOUS Medicare Data Bank, which Congress last year finally put out of its misery, coming back?

In all honesty, we can't tell for sure, but there are some worrisome signs.

As we reported earlier this month, budget documents the Clinton administration released say legislation is being drafted that would require a "beneficiary's other insurance plan to tell Medicare when that beneficiary is covered."

When we called the Health Care Financing Administration for clarification, we received conflicting reports.

One HCFA staffer said insurers and plan administrators-though not employers-would be required to provide the agency with enrollment information on all employees and dependents enrolled in their group health care plans.

A second HCFA staffer said coverage information, such as names and dates of birth, would be sought only for employees and dependents eligible for Medicare, chiefly those at least 65 years old.

Yet another HCFA staffer, while not offering any details, said any new health care plan coverage or enrollment requirement would not impose any significant new administrative burdens on employers or insurers.

It isn't surprising, we suppose, that conflicting information can emerge from government officials when a proposal is being drafted. It is possible, for example, that the officials interviewed had different versions of the proposals.

But what is disturbing is that the administration is considering imposing new health care coverage enrollment requirements on insurers and plan administrators, if not on employers.

Before proposing such a new requirement, administration officials should look at the brief history of the proposal's predecessor, the Medicare Data Bank, and why the Data Bank ultimately was repealed.

The Data Bank originally was tucked into a 1993 budget law. It was supposed to save Medicare billions of dollars. Unfortunately, the way it was put together, we doubt if it would have saved the government anything.

Under the Data Bank, employers were required to file with HCFA health care coverage information for all their employees and dependents.

The idea was that having access to this information would enable government regulators to spot certain situations when a group plan should be the primary payer of hospital and physician bills, rather than Medicare-for instance, when employees are still working after turning 65.

The only problem with this requirement is that it would have flooded the government with health care coverage enrollment information for the roughly 160 million people in group plans. There is no way-not even with the fastest computers-that so much information could have been used for its intended purpose of reducing incorrect Medicare payments.

Employers got that message home, and Congress, after years of delaying the implementation of the Data Bank, repealed it last year.

As to the new proposals-take your pick as to which one the administration will advance-they also are flawed, just like the Data Bank was.

If a reporting requirement covering all employees and dependents is imposed, this time on insurers and plan administrators rather than employers, the government still will end up with tens of millions of useless forms.

Even if the reporting requirement is limited to those employees and dependents eligible for Medicare, we still see problems.

No doubt insurers or plan administrators know when employees turn 65 and are eligible for Medicare. But what would happen if an older worker changed jobs during the year? Would each plan administrator have to file a report? What would happen in a situation where a worker retired at 65 and then changed his mind and returned to work? Would a report also be required? No doubt reporting problems would develop in many other situations.

Certainly, the more sensible approach is vigorous government enforcement of rules that require hospitals to verify group health insurance coverage of a patient, particularly someone over 65, before billing Medicare.

Billing the right parties at the start seems a lot more logical than collecting a mass of forms, many of them useless and all of them expensive to prepare and analyze.

We hope the Clinton administration rethinks this proposal.