CMS Extends Deadlines for Non-Group Health Plans under MMSEA Section 111 Mandatory Reporting Requirements

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6/2/2009
CMS has revised the implementation timeline for liability Insurance (including self-insurance), no-fault Insurance, and workers' compensation (Non-Group Health Plans or NGHPs) under the Medicare Secondary Payer Mandatory Reporting Provisions in Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007  (MMSEA).  For a more detailed description of the MMSEA Section 111 mandatory reporting requirements for NGHPs, please see the May 2009 Waller Lansden bulletin at this link.
 
Under the new implementation timeline, Responsible Reporting Entities (RREs) for NGHPs now have from May 1, 2009 through Sept. 30, 2009  to register.  The testing period for the submission of the Claim Input File has been extended and will now take place from Jan. 1, 2010 through March 31, 2010.  The timeframe for the submission of live reports also has been pushed back, and RREs now must submit their first live production file no later than their assigned submission window for the April - June calendar quarter of 2010.   
 
CMS also announced that Section 111 reporting will not include the reporting of Total Payment Obligation to the Claimant (TPOC) amounts with dates prior to Jan. 1, 2010.
 
For more information on MMSEA Section 111 Mandatory Reporting Requirements, please contact Neil Krugman, Josh Collins or any other member of the Waller Lansden Healthcare practice at 800-487-6380.

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