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 - 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 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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Section 111 Civil Monetary Penalty Rulemaking Update

On Friday, September 22nd, the White House Office of Management and Budget published a notice that provided that the review of the Medicare Secondary Payer Section 111 Reporting Civil Monetary Penalty Final Rule has been completed. As such, it is likely that the final rule will be published in the Federal Register very soon.
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New Maximum Settlement Amount for Fixed Percentage Demand Calculation Option

Commencing October 2, 2023, the new maximum settlement amount for the Fixed Percentage Option (FPO) will be $10,000. This is double the current maximum settlement amount for the FPO of $5,000. The function of a FPO in Medicare conditional payments cases is...
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