Author: Ciara Koba, Esq.
CMS has finalized what will arguably be the most significant rulemaking the Medicare Secondary Payer industry has ever had. The final rule specifies how and when Group Health Plan and Non-Group Health Plan reporting entities will be penalized civilly for failure to comply with Section 111 reporting requirements. A high-level outline of the highlights of this rule as it applies to Non-Group Health Plans (NGHPs) and the impact to the carrier community can be found below. To read the full text of the final rule, click here.
To discuss this rule in more detail with a member of the Allan Koba Compliance Section 111 Reporting Team, please email info@allankoba.com and we will be happy to schedule a meeting.
Overview of the Final Rule on Section 111 Civil Monetary Penalties (CMPs) for NGHPs:
