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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CMS Releases Updated NGHP Section 111 User Guide, Version 7.3

CMS has continued the recent onslaught of Section 111 Reporting updates with the release of the latest iteration of the Non-Group Health Plan User Guide – Version 7.3. Given other recent updates, alerts, and townhall conferences held, this does not come as a surprise. Version 7.3 contains three main revisions...
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Section 111 Mandatory Insurer Reporting Update: Top 10 Errors and Empty NGHP Unsolicited Response Files

CMS has released an updated list of the Top 10 Section 111 NGHP Reporting error codes based on data from January to June 2023. Noteworthy errors include invalid Termination Date and Invalid Diagnosis Code 1, impacting conditional payment recovery. The total number of errors increased compared to the previous period, and CMS clarified that opted-in RREs will receive blank response files if no data is available, as per a recent alert...
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