Our Insights

CMS opened 2023 with a series of updates to the NGHP Section 111 User Guide. First, on January 9, a new version of the User Guide – version 7.0 – was published. While several of the updates contained in this new iteration were informative only, including confirmation that the $750 settlement threshold will stay the […]

As what remains of 2022 dwindles into a new year, trending on the Medicare Conditional Payment front garners attention from industry stakeholders. Mounting concerns surrounding Civil Monetary Penalties associated with Section 111 Medicare Mandatory Insurer reporting (rulemaking anticipated by or before February 2023) could increase vigilance and reporting efforts. Additionally,  a recent OIG audit, which […]

CMS will now provide RREs, as well as their Recovery Agents, with the option to go paperless with respect to Medicare recovery correspondence. In an updated NGHP Section 111 User Guide release, version 6.7, CMS states that insurers and their recovery agents may elect to receive electronic correspondence so long as a Medicare Secondary Payer […]

Over recent weeks, CMS has posted a duo of alerts to the Non-Group Health Plan Mandatory Insurer Reporting landing page. While these alerts do not place any new obligations or requirements on Responsible Reporting Entities, they do provide some helpful reminders, coupled with a bit of guidance. The first alert, released October 26, 2021, provides […]

Two weeks in advance of its PAID Act webinar, CMS has released an updated NGHP Section 111 User Guide.  While the latest version contains several updates, the most intriguing and most impactful may be the announcement that the changes to the Medicare entitlement information provided via the Section 111 query process outlined by the PAID […]

In the fourth iteration of the NGHP Section 111 User Guide in six months, CMS has issued several updates, mainly affecting technical aspects of Section 111 reporting. The bulk of these updates attempt to clarify how and when errors will be received through the reporting process. As we know, the proposed regulations regarding civil monetary […]