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Medicare Section 111 process change eases one compliance burden

Medicare’s annual recertification process and update brings welcome news about Section 111 reporting and Responsible Reporting Entities (RREs). RREs will no longer automatically be moved into “discontinued” status if they fail to provide Medicare the requested annual recertification information.

We became aware of some modifications in the recertification process and we asked Medicare about the changes. We received a written response from Medicare that included:

  • The language in recertification emails has been modified and no longer includes mention of RREs being placed in discontinued status if they fail to recertify
  • There is no official announcement from Medicare about this change
  • Medicare stressed that it is critical for RREs to continue to ensure their Profile Reports are current and up-to-date

Medicare will still send notices about the need to recertify the Profile Report. Medicare’s updated recertification process and emails still provide the following:

  • The Profile Report must be recertified at the beginning of each 12-month period
  • If the information in the Profile Report is current and accurate, then a call or email to the RRE’s EDI representative is sufficient to confirm the recertification requirement
  • Any changes or updates to the Profile Report must be provided to the EDI representative and a new Profile Report will be issued, which must be signed and returned by the Authorized Representative
  • The RRE should confirm its recertification within 10 days of receiving notice from Medicare
  • Failure to recertify places the RRE at risk of non-compliance

Although it is still critical that RREs recertify annually, Medicare’s change may help some RREs remain in “production” status instead of being placed into "discontinued" status due to administrative oversights. As a result, some RREs may still have the ability to submit files to Medicare without unnecessarily being locked out of the Section 111 reporting process.

Any current RRE that is in "discontinued" status should take the necessary steps to ensure it is moved into "production" status and that its Profile Report is current and accurate. Section 111 compliance cannot be achieved if an RRE is in "discontinued" status because no files can be sent or processed.

Contact us for any questions about the recertification process.

Shawn Deane

Shawn Deane is vice president of Medicare / Medicaid compliance and policy at ISO Claims Partners, a Verisk business. You can contact Shawn at

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