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CMS Updates Section 111 Implementation Timeline

On May 11, 2009, The Centers for Medicare and Medicaid Services (CMS) announced several changes relating to Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA). These changes include an update to the implementation timeline, as well as updates on reporting thresholds for Total Payment Obligations to Claimants, or TPOCs.

With the release of this memo, the registration period for liability insurance (including self-insurance, no-fault insurance, and workers’ compensation RREs) has been extended. RREs now have from May 1, 2009 through September 30, 2009 to register. Consequently the testing period will now take place from January 1, 2010 through March 31, 2010, with first live files now scheduled to be submitted in the April-June quarter of 2010.

There have also been some changes relating to the TPOCs. The CMS has now determined that the Section 111 reporting will not include the reporting of TPOC amounts with dates prior to January 1, 2010. If a TPOC amount dated on or after January 1, 2010 falls below the threshold amount, the RRE is to add all associated TPOC amounts dated on or after January 1, 2010 in determining if the reporting threshold is met. Any associated TPOC amount occurring prior to January 1, 2010 should not be considered when calculating the TPOC amount for purposes of the reporting threshold. However, The CMS has also stated within this memo that although RREs are not required to report TPOCs where the applicable TPOC date is prior to January 1, 2010, a record will not be rejected based upon a TPOC date before January 1, 2010.

To view this memo in its entirety, please click here.

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