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. A snapshot of the top 10 errors is as follows:     While three […]

In a recent publication, the U.S. Attorney’s Office for the District of Maryland has confirmed that a Baltimore-based firm – Kandel & Associates, P.A. has entered into a settlement agreement to resolve alleged claims that the firm failed to reimburse Medicare for conditional payments made by CMS on behalf of firm clients. The claims against […]

A recent change to a Medicare Secondary Payer Manual brings Medicare Set-Asides into play for doctors and other medical service providers, who as of March 24 are obligated to direct bill those trusts. Just a year after Medicare’s Workers’ Compensation Medicare Set-Aside Reference Guide update strenuously emphasized the utility of MSAs in protecting Beneficiary entitlements […]

Practice Alert!   Effective March 13, 2023, the Centers for Medicare and Medicaid Services has issued an announcement that the mailing address has changed for Medicare’s Commercial Repayment Center (CRC).   The CRC handles all liens for cases wherein Medicare considers the insurer/employer to be the debtor.   Please note the new mailing address for Group […]

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 […]