Our Insights

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. While three of the top ten errors are “soft errors” and will not trigger […]

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 […]

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 […]