Our Insights

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 […]

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 […]

On Friday, September 22nd, the White House Office of Management and Budget published a notice (see image below) indicating the review of the Medicare Secondary Payer (MSP) 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 […]

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: First, and arguably the most […]

CMS has recently published an updated list of the Top 10 Section 111 NGHP Reporting error codes. This list is based on data received from January 1, 2023 through June 30, 2023. While the full breakdown can be found here – https://www.cms.gov/medicare/coordination-of-benefits-and-recovery/mandatory-insurer-reporting-for-non-group-health-plans/whats-new/whats-new. A snapshot of the top 10 errors is as follows:     While three […]

Non-Group Health Plan reporting entities have been waiting for over a decade for clarification on when and how civil monetary penalties (CMPs) for non-compliance with the Section 111 reporting guidelines will be assessed.  The proposed rule that will specify how and when CMS must calculate and impose CMPs was published on February 18, 2020 and can be […]