Section 111

CMS releases new NGHP Section 111 User Guide (Version 5.7)

The Centers for Medicare and Medicaid Services (CMS) has released an updated  Section 111 User Guide (Version 5.7, October 7, 2019)   regarding non-group health plans (liability, no-fault and workers’ compensation)....

Ninth Circuit: CIGA is not a “primary payer” under the MSP and does not have to reimburse Medicare

In a significant new case out of California, the United States Circuit Court of Appeals (Ninth Circuit) [1] in California Insurance Guarantee Association (CIGA) v. Azar , 2019 WL 5076945 (9 th Cir. Oct. 10, 2019)...

Conditional Payment Updates | Open Debt Reports are back; Pre-PCN worksheets are on hold; and CRC will continue to review all CPL disputes

There has been a flurry of recent activity from the Centers for Medicare and Medicaid Services (CMS) and the Commercial Repayment Center (CRC) regarding processing of conditional payment claims.  The new CMS and CRC...

CMS’ Section 111 Penalty Proposals Are One Step Closer

A new release from the Office of Information and Regulatory Affairs (OIRA) indicates that the Centers for Medicare and Medicaid Services (CMS) is one step closer to releasing its much-anticipated Section 111 reporting...

CRC looks to resolve backload of conditional payment leads

On August 9, 2019, the Commercial Repayment Center (CRC) hosted a conference call to discuss the handling of conditional payment letters (CPL) versus conditional payment notices (CPN). On this call, the CRC announced...

CMS releases new NGHP Section 111 User Guide (Version 5.6)

The Centers for Medicare and Medicaid Services (CMS) has released an updated Section 111 User Guide (Version 5.6, July 1, 2019 ) regarding non-group health plans (liability, no-fault and workers’ compensation). This...

PAID Act Introduced in the U.S. Senate

On June 26, 2019, Senators Tim Scott (R-SC) and Ben Cardin (D-MD) introduced Senate Bill 1989 into the U.S. Senate. Section one of this bill states the Act may be cited as the Provide Accurate Information Directly (PA...

Think about Your Thresholds: Preventing Errors to Avoid CMS Penalties

We’ve been taking a look at some of the ways RREs can attempt to achieve full CMS compliance and avoid potential penalties that may be coming soon. One area to consider more closely is file thresholds. Upon submission...

Big reforms are coming to Michigan PIP - How the changes will impact Medicare Secondary Payer compliance

On May 30, 2019, Michigan Governor Gretchen Whitmer signed into law Michigan Senate Bill 1 (S.B. 1) [1] which makes significant changes to Michigan’s personal injury protection (PIP) system, including allowing policy...

With Civil Money Penalties Looming, It’s Time to Fine-Tune CMS Reporting

For insurance carriers and self-insureds—known as Responsible Reporting Entities (RREs)—Section 111 can be a daunting obligation. In fact, it’s the only Medicare Secondary Payer (MSP) compliance area associated with a...