MSP Compliance Blog


Expert summary, analysis and recommendations on issues impacting Medicare Secondary Payer compliance.

CMS Provides Notices on Section 111 Reporting and Conditional Payment Processes

Posted on June 17, 2020 by Tower MSA

CMS has recently issued two notices, one pertaining to Section 111 mandatory insurer reporting and one relevant to Medicare conditional payment recovery.

First, in a “teaser” notice, CMS announced that on July 13, 2020 the Medicare Secondary Payer Recovery Portal (MSPRP) is scheduled to be enhanced to allow authorized users to view and print correspondence.

According to the notice,

MSPRP users who log in using Multi Factor Authentication will be able to view and print CMS mailed correspondence that is displayed on the Letter Activity tab. Additional information on how to use this new functionality will be available in Section 14.1.1.4 of the July version of the MSPRP User Guide.

Second, in an alert entitled “Reporting No-Fault Insurance Limit on Non-Group Health Plan (NGHP) Claim Input Files,” CMS reminds Responsible Reporting Entities (RREs) that they must combine both Med Pay and Personal Injury Protection (PIP) coverage limits for Section 111 repotting purposes.  This would be under circumstances where separate Med Pay and PIP coverages are being paid out on claims for the same injured party and incident under a single policy.

CMS also reminded RREs that ORM cannot be terminated until both Med Pay and PIP coverage limits are exhausted.  Further, that when providing the dollar amount for the policy limit, that it must accurately reflect two decimal places.  For example, a policy limits of $5,000 should be reported as 500000.

Practical Implications

In regard to the MSPRP enhancement to print documents, while we will have to see the specific guidance in the July update, this may prove quite useful in not having to wait for correspondence to come in the mail, print letters that were not received via the mail or reprint letters.

As for the alert to remind No-Fault carriers to report Med Pay and PIP coverage limits as a combined amount, while this guidance is already included in the NGHP User Guide, there was apparently some confusion that led CMS to provide this alert as a reminder of how such coverage must be reported.

If you have any questions, please contact Dan Anders, Chief Compliance Officer at daniel.anders@towermsa.com or 888.331.4941.