Jeremy Farquhar

9/25/2024 - 13 min read

Voluntary Testing for TPOC/WCMSA Reporting Starts October 7, 2024

Reminder for Section 111 NGHP RREs: CMS’s voluntary testing for the new TPOC/WCMSA reporting starts October 7, 2024.

9/25/2024 - 8 min read

CMS’s CMPs Final Rule is “Applicable” October 11, 2024

CMS's CMPs final rule becomes “applicable” on October 11^th regarding Section 111 penalties.

9/18/2024 - 19 min read

CMS Covers NGHP Section 111 Reporting Issues in September 12 Webinar

On September 12, CMS’s NGHP Section 111 webinar covered TPOC reporting triggers, the TPOC/WCMSA process, and other updates.

9/17/2024 - 13 min read

CMS’s Section 111 Daily CMPs Max Rate for NGHP Reporting is Now $1,474

A new Section 111 update raises the maximum daily CMP for NGHP reporting.

4/26/2024 - 14 min read

CMS Holds a TPOC/WCMSA “Question & Answer” Session to Further Discuss its New Section 111 Reporting Process

On April 25th, CMS held a “Q and A” session to discuss its plans to require S.111 RREs to report various WCMSA data points as part of its TPOC reporting trigger.

4/17/2024 - 13 min read

CMS' Second TPOC/WCMSA Webinar Unveils Key Updates to Section 111 Reporting

CMS' second webinar unveils plans for Section 111 RREs to include WCMSA data points in TPOC reporting trigger.

4/3/2024 - 12 min read

CMS Releases S.111 NGHP User Guide Version 7.5

CMS has released an updated Section 111 NGHP User Guide (Version 7.5, April 1, 2024) regarding S.111 reporting related to NGHPs.

2/26/2024 - 7 min read

CMS Releases New Information About TPOC/WCMSA Data Collection Process

A February Alert provided more information on CMS’s plans to require RREs to report WCMSA data as part of its TPOC reporting trigger.

1/30/2024 - 21 min read

CMS Releases Section 111 NGHP User Guide (Version 7.4)

CMS released an updated Section 111 NGHP User Guide (Version 7.4) regarding reporting related to non-group health plans (NGHPs).

1/23/2024 - 20 min read

CMS Discusses NGHP Section 111 Civil Money Penalties on its First CMPs Webinar

CMS’s Section 111 ‘penalties’ webinar discussed different CMPs changes, including, how CMPs will be calculated, the audit process, notice/appeal, and safe harbors.

12/7/2023 - 11 min read

Breaking Down CMS’s Plans to Capture WCMSA Data

CMS has announced plans to require Section 111 RREs to report various data points related to WCMSA arrangements

11/29/2023 - 8 min read

CMS Corrects Minor “Technical Errors” in the Section 111 Penalties

In a new development, CMS has issued an update which corrects certain “technical errors” in the Section 111 final rule.

11/16/2023 - 10 min read

CMS Discusses Plans to Capture WCMSA Data Points as Part of TPOC Reporting During Recent Section 111 Webinar

CMS held a webinar to discuss its plans to require Section 111 (RREs) to report data points related to WCMSAs

11/7/2023 - 15 min read

CMS Releases New Section 111 Penalties FAQ Resource

CMS has now released a new Alert entitled CMS’s Medicare Secondary Payer and Certain Civil Money Penalties: Frequently Asked Questions

10/11/2023 - 24 min read

CMS’s Section 111 Penalties “Final Rule” Released – Breaking Down CMS’s Penalty Provisions and How They Impact Section 111 Reporting

In an important development, CMS has released its Section 111 penalties “Final Rule” --- CMS penalties will go live in 60 days.