Category Archives: Medicare Reporting Section 111

Blog, Medicare Conditional Payments, TPOC

As required by Section 202 of the SMART Act, CMS is required to annually review its costs relating to recovering conditional payments as compared to recovery amounts. Since 2017, CMS has maintained its threshold of $750.00 across all Non-Group Health Plan (NGHP) lines of business to include workers’ compensation, general liability, and no-fault insurance.  The threshold means that in scenarios …
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Blog, Legal/Legislative News, LMSA, Medicare Reporting Section 111, Medicare Set Aside

We have previously blogged regarding two Notice of Proposed Rulemakings (NPRMs) regarding Section 111 Civil Monetary Penalties and MSP and Future Medicals (which will propose options for LMSAs and/or protecting Medicare’s future interest in General Liability claims) pending on the Office of Management and Budget (OMB)’s website. Our prior blog on the Section 111 rulemaking can be found here and …
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Blog, Legal/Legislative News, Medicare Jurisdiction, Medicare Reporting Section 111, Medicare Secondary Payer News

The Medicare Advocacy Recovery Coalition (MARC) has announced that the Provide Accurate Information Directly (PAID) Act was introduced yesterday, February 27, 2019 in the U.S. House of Representatives as H.R. 1375 by lead Co-Sponsors Reps. Ron Kind (D-WI) and Gus Bilirakis (R-FL). Representatives Kind and Bilirakis have sponsored this bipartisan legislation to improve the Medicare Secondary Payer Act (MSP). PAID’s …
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Blog, Medicare Reporting Section 111, Medicare Secondary Payer News, RRE

The Centers for Medicare & Medicaid Services (CMS) has issued yet another abundantly clear signal that Medicare Secondary Payer (MSP) enforcement will be a priority in 2019. Just last week, we blogged that a Proposed Rule on a voluntary review process for Liability Medicare Set-Asides (LMSAs) would be issued by September 2019. Now, an additional notice on the Office of Management and …
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Blog, Medicare Reporting Section 111, ORM

In our oversight of numerous MMSEA Section 111 programs nationwide, we frequently answer many questions from clients surrounding Ongoing Responsibility for Medical (ORM). The confusion is understandable as ORM can be complicated. Let’s explore the various types of questions that we most often receive: What constitutes ORM? CMS defines ORM as a Responsible Reporting Entity (RRE)’s responsibility to pay for …
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Blog, Medicare Reporting Section 111, ORM, RRE, TPOC

We recently blogged regarding CMS releasing their updated NGHP User Guide version 5.3. The primary change outlined in the Summary of Changes in the User Guide was regarding CMS’ SSNRI initiative which will ultimately replace the use of SSN’s with MBIs. For more information, our prior blog can be found here. It appears that CMS has also modified another section of …
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CMS Releases Updated NGHP User Guide Version 5.3

27 Dec 2017 Heather Sanderson No Comments

Blog, Legal/Legislative News, Medicare Conditional Payments, Medicare Reporting Section 111, Medicare Secondary Payer News

CMS has released an updated Non-Group Health Plan (NGHP) User Guide version 5.3. It can be found here. The primary change to the User Guide involves detailing CMS’ transition with its Social Security Number Removal Initiative (SSNRI) and how this transition will impact MMSEA Section 111 Reporting. The SSNRI initiative mandates CMS to replace all SSN-based Medicare identifiers and distribute a …
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Blog, Medicare Conditional Payments, Medicare Secondary Payer News, TPOC

As required by section 202 of The SMART Act, CMS is required to annually review its costs relating to recovering conditional payments as compared to recovery amounts. Last year in 2016, CMS announced that the threshold would be $750 across all non-group health plan (NGHP) lines of business- workers’ compensation, liability, and no-fault insurance. The threshold means that if the …
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The Grinding Gears of CMS Regulation

27 Jun 2017 John Williams No Comments

Blog, Franco Signor News, Legal/Legislative News, Medicare Conditional Payments, Medicare Reporting Section 111, Medicare Secondary Payer News, Medicare Set Aside

The Grinding Gears of CMS Regulation A CLM Magazine Article by John Williams and Heather Sanderson Personal Injury and No-Fault Payers Should be Aware of Three Compliance Issues  As the Centers for Medicare and Medicaid Services (CMS) faces mounting pressure to address financial challenges, the agency is looking for methods to recover over-payments and ensure that it does not make a …
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Blog, Legal/Legislative News, Medicare Reporting Section 111

In a decision out of the Superior Court of Connecticut, Silver v. Miliford Medical Center Associates, 2017 Conn. Super. LEXIS 899 (May 11, 2017), a defendant medical provider filed a motion to compel the Plaintiff to respond to supplemental discovery so that its insurer could comply with the requisite requirements of MMSEA Section 111. Essentially, the medical provider’s insurer, which …
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