Section 111 Reporting

6/16/2020 - 9 min read

Key changes to Michigan PIP start July 1, 2020 – Medicare Secondary Payer compliance impact

While individuals will still be able to elect unlimited PIP coverage, for applicable policies issued or renewed after 7/1/20, PIP plans with different coverage limits may also now be purchased.

6/12/2020 - 2 min read

CMS releases Section 111 alert regarding the reporting of no-fault insurance and med-pay policy limits on claim input files

Limits on NGHP claim input files in situations where separate Med-Pay and PIP coverages being paid out under a single policy for the same injured party and incident.

5/1/2020 - 19 min read

Court finds state of Rhode Island compliant with Section 111 despite its inability to obtain social security information to determine Medicare status and enforces settlement

The U.S. District Court in Ruiz v. Rhode Island was called upon to address whether a personal injury settlement should be enforced even though the defendant was unable to obtain the plaintiff’s social security number, or the last five digits of his SSN, to determine his Medicare status through CMS’s Section 111 Query Process.

4/21/2020 - 8 min read

CMS’s Section 111 civil money penalties comment period closes

With the comment period closed, the focus now turns to when CMS will issue its Final Rule, which will comprise of the agency’s official CMP regulations.

4/9/2020 - 1 min read

Medicare enables COVID-19 ICD-10 code for Section 111 reporting

The CDC issued a bulletin advising it is implementing the new ICD-10 U07.1 for “COVID-19, virus identified” in an off-cycle update effective 4/1/20, to code the COVID-19 diagnosis.

3/30/2020 - 9 min read

Settling claims in unsettling times

In a time of social distancing and uncertainty, many are left wondering how our current working and social paradigm will impact workers’ compensation claims handling – especially being able to close claims.

2/18/2020 - 12 min read

CMS’s Section 111 penalty proposals are here

CMS has released its long-awaited Section 111 civil money penalty proposals for non-group health plans, as well as group health plans.

11/21/2019 - 3 min read

Release of CMS’s Section 111 penalty proposals delayed again – pushed back to December

OIRA announced CMS’s expected release of its Notice of Proposed Rulemaking proposals for Section 111 civil money penalties has been pushed to December 2019.

11/20/2019 - 4 min read

CMS’s new Section 111 alert addresses MBI reporting

CMS has issued an updated Section 111 Alert pertaining to non-group health claims (NGHP) regarding the Medicare Beneficiary Identifier (MBI) reporting.

10/23/2019 - 1 min read

CMS releases new NGHP Section 111 user guide (Version 5.7)

On 10/7/19, CMS released an updated Section 111 User Guide (Version 5.7) regarding non-group health plans (liability, no-fault and workers’ compensation).

10/11/2019 - 8 min read

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 (9th Cir. Oct. 10, 2019) reversed the United States District Court for the Central District Court of California [2] and ruled that CIGA is not a “primary plan” under the Medicare Secondary Payer (MSP) statute and, therefore, not liable to reimburse Medicare conditional payments made on behalf of workers’ compensation claimants.

10/7/2019 - 7 min read

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.

Jubal Kenneth Bernal Uvdhvgaeem4 Unsplash

7/15/2019 - 1 min read

CMS releases new NGHP Section 111 user guide (Version 5.6)

On 7/1/19, CMS released an updated Section 111 User Guide (Version 5.6) regarding non-group health plans (liability, no-fault and workers’ compensation).

6/27/2019 - 4 min read

Think about your thresholds: Preventing errors to avoid CMS penalties

One way responsible reporting entities can attempt to achieve full CMS compliance and avoid potential penalties is to closely consider file thresholds.

Beatriz Perez Moya Xn4t2pvuugk Unsplash 1

6/17/2019 - 6 min read

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

On 5/30/19, Governor Gretchen Whitmer signed Michigan Senate Bill 1, which makes significant changes to Michigan’s personal injury protection (PIP) system.