Our Insights

CMS opened 2026 with additional clarity on the Civil Money Penalty (CMP) enforcement timeline during its January 15th webinar, offering important operational details for Responsible Reporting Entities (RREs) preparing for the first audits under the Section 111 Final Rule. While much of the rule’s framework has already been published, CMS used this session to reinforce […]

To start 2026, CMS released Version 8.3 of the MMSEA Section 111 NGHP User Guide just five days into the year. Although not a voluminous overhaul, this update delivers several key clarifications and reminders that Responsible Reporting Entities should review carefully.   What’s New in Version 8.3? Medicare Query Result Clarification (Chapters I, II & IV) CMS […]

CMS has released an updated version of the NGHP Section 111 User Guide, introducing critical clarifications and new requirements that impact reporting. Staying ahead of these changes is essential to avoid compliance risks and potential penalties. Below is a summary of the most significant updates that require your immediate attention.   Key Highlights from the […]

In a recent Medicare conditional payments case involving a 1999 asbestos settlement, Allan Koba Compliance Solutions successfully navigated a series of legal and procedural challenges to deliver over $54,000 in savings to the client. Case Facts Claimant sustained work-related exposure to asbestos in 1993.  The workers’ compensation claim settled in 1999.  Twenty-six years later, Medicare’s […]

In a pivotal ruling from the Eastern District of Pennsylvania, CVS Caremark finds itself in hot water, facing significant repercussions for allegedly manipulating prescription drug pricing. (See:  United States of America ex rel. Sarah Behnke v. CVS Caremark Corporation, No. 14‑cv-824 (E.D. Pa. June 25, 2025)  This high-stakes case, initiated by former Aetna actuary Sarah […]

Life Care Planning: Bringing Clarity to Life’s Toughest Moments When a catastrophic injury or chronic illness turns life upside down, navigating the future can feel overwhelming. That’s where Life Care Planning steps in—with compassion, clarity, and expert guidance. At Allan Koba, our Certified Life Care Planners are experienced medical professionals who work hand-in-hand with attorneys, […]