Updated NGHP User Guide Outlines New Warning Flag for Open ORM Claims

On October 7th, CMS released Version 7.7 of the MMSEA NGHP User Guide with a few key updates. This iteration adds additional information regarding the steps needed and the emails that are issued during RRE registration, specifically Ch. 1 Table 7-1, Ch. 2 Table 6-4, and Ch. 4 Table 12-1. In general, these tables provide an easy-to-read overview of the registration process from TIN input, to PIN verification, and RRE vetting. Version 7.7 also adds some clarity to the reporting of wrongful death claims. Ch. 3 has added a note indicating...
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CMS Announces Updates to Section 111 COBSW Portal

On August 8th, CMS issued an alert confirming that COBSW system updates are coming soon. The Section 111 Coordination of Benefits Secure Website (COBSW) provides general information on Section 111 reporting, links and instructions, reference materials including various user guides, as well as a secure portal which provides the ability to manage your RREs, run Medicare entitlement queries, perform DDE reporting, and obtain query and claim response files. The upgrades...
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CMS Releases NGHP Section 111 User Guide Version 7.4 and Top Ten Reporting Errors from 2023

CMS has released its first version of the Non-Group Health Plan Section 111 Reporting User Guide of 2024. Not long after a recent informational webinar regarding Civil Monetary Penalties held on January 18, CMS released version 7.4 of the User Guide, in which the primary update is the addition of Ch. III, sect. 5.1 - Civil Monetary Penalties. This addition does not contain any surprise details that were not a part of the informational webinar, or prior communications regarding CMPs, but rather provides a general overview of what may subject an RRE to penalties, when, and how, as well as a description of CMS’ audit methodology. The full update can be found here - https://www.cms.gov/medicare/coordination-benefits-recovery/mandatory-insurer-reporting/user-guide. However, a brief summary of the additions outlined in section 5.1 are:
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Recap of NGHP Section 111 Reporting CMS Webinar on Civil Monetary Penalties

CMS hosted a live webinar on January 18th at 1pm EST. This webinar provided valuable information for responsible reporting entities (RREs) as the industry prepares for CMS to begin quarterly compliance audits and the imposition of civil monetary penalties. Please find the highlights of the webinar below and if you have further questions about your Section 111 reporting program and what you can do now to get ready for CMS audits, please reach out to info@allankoba.com and we can assist. Our Section 111 Reporting audit team is ready to help RREs ensure proper reporting and avoid civil monetary penalties.
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CMS Announces Webinar Regarding Changes to Section 111 Reporting and Releases Updated ICD Codes for 2024

CMS has announced that it will be hosting a webinar on November 13th, 2023, regarding a coming expansion to Section 111 reporting. Specifically, the announcement indicates that expansion will involve expanding TPOC reporting to include WCMSA information. The webinar will include a presentation by CMS providing general information and timelines, and should also permit for Q&A.
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ALERT: Overview of the Final Rule on Section 111 Civil Monetary Penalties (CMPs) for NGHPs

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.
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