CMS Extends Section 111 Reporting Deadline and Dollar Thresholds

The Centers for Medicaid and Medicare Services (CMS) just announced another extension of the reporting deadline for the Medicare Secondary Payer (MSP) Mandatory Insurer Reporting (MIR) provisions in Section 111 of the Medicare, Medicaid, and SCHIP Extension Act (MMSEA) of 2007.   In an Alert dated November 9, 2010, CMS announced the following three timetable extensions.

TPOC Reporting Date changed to Q1, 2012 for Liability Insurance
The required submission date for liability insurance Total Payment Obligation to Claimant (TPOC) initial reports have been changed from the first calendar quarter of 2011 to the first calendar quarter of 2012.  TPOC refers to the dollar amount of a settlement, judgment, award or other payment intended to resolve or partially resolve a claim.

TPOC Capture Date changed to 10/1/2011 for Liability Insurance
The current rule requiring reporting on Non Group Health Plan (NGHP) TPOC dates starting on 10/01/2010 has been changed to 10/01/2011.

Dollar Threshold Dates are Extended One Year for both Liability and Workers’ Compensation Insurance
All dollar threshold dates for liability insurance and workers’ compensation have been extended by one year.  The new thresholds are as follows:

  • TPOC dates prior to 1/1/2013, with TPOC amounts of $0.00-$5,000.00, are exempt from reporting.
  • TPOC dates from 1/1/2013 through 12/31/2013, with TPOC amounts of $0.00 to $2,000.00, are exempt from reporting.
  • TPOC dates from 1/1/2014 through 12/31/2014, with TPOC amounts of $0.00 to $600.00, are exempt from reporting.
  • No threshold applies for TPOC dates on or after 1/1/2015.

It is important to note that this delay only applies to liability insurance reporting of TPOCs and dollar threshold dates for both liability and workers’ compensation insurance. Ongoing Responsibility for Medicals (ORM) reporting remains the same. Also, although the deadline has changed, early reporting is welcome, encouraged and will be accepted.

View the Alert here


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