Our Insights

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 […]

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 […]

On November 14, 2022, CMS released version 3.8 of the WCMSA Reference Guide. If you attended the Medicare Secondary Payer Network 2022 Annual Conference (The National Medicare Secondary Payer Network) in September, you may have been anxiously anticipating the release of this updated guide with the hope that clarification on re-review requests would be provided […]

Following the release of the updated Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) Reference Guide, Version 3.5, dated January 10, 2022, we have been waiting for CMS to announce a webinar to discuss the clarification on use of non-CMS approved products to address future medical care that this updated guide contained.  According to the Webinar Announcement […]