On April 7, 2009 CMS issued an alert changing how non-GHP RREs will report multiple TPOC dates and amounts on the claim input file for Section 111 reporting.

CMS has attempted to clear up the confusing nature of reporting multiple Total Payment Obligations to the Claimant, or TPOC. The previous information left doubt as to how an RRE would report updates to multiple TPOC amounts that had already been reported. The new memo provides the following example:

Suppose a TPOC Amount and Date were reported on an add record for a Workers’ Compensation indemnity settlement and subsequently an update record was submitted with an Action Type of ‘3’ to report a different, additional TPOC Amount and Date, for the same claim, reflecting a settlement for lost wages. The current file layout and processing requirements do not provide the flexibility for an RRE to subsequently update one of these specific TPOC Amounts and/or Dates if necessary.

Previously it was thought that in order to update an already reported record, the RRE would have to enter a 3 in the “Action Type” field. However, at that point the RRE was not given any option to update those files if necessary. The new process has eliminated the option to enter a 3. Instead four additional TPOC amount fields as well as the corresponding TPOC date fields have been added to the end of the Claim Input File Auxillary Record layout. In addition, a “Funding Delayed Beyond Start Date” field has also been added. These new fields only need to be submitted if the RRE has more than one additional TPOC to report for a claim. For additional details on this update, please click here.