Tower’s Section 111 Reporting Audit Service Can Help You Fix Systemic Issues and Avoid Penalties. Workers’ compensation payers and other Responsible Reporting Entities (RREs) have a little over five months to get their Section 111 reporting houses in order. And Tower’s Section 111 reporting audit service is here to help you clean things up.

Section 111 reporting – a bit of background

Starting October 11, 2024, RREs, which are workers’ compensation plans, liability insurance (including self-insurance) and no-fault insurance) will be held accountable for the timely reporting of Medicare beneficiary claimants where ongoing responsibility for medicals (ORM) has been accepted or where a Total Payment Obligation to the Claimant (TPOC) has occurred. Civil Money Penalties (CMPs) for untimely reporting of ORM acceptance or TPOC can be thousands of dollars on a single claim.

Three reasons to have Tower audit your Section 111 reporting

1. Catch the type of errors, omissions and inconsistencies that could trigger thousands of dollars in penalties.
2. Eliminate systemic flaws that lead to time-consuming and unnecessary conditional payment demands
3. Help you correct human and technology processes and procedures so you can avoid future reporting errors

What’s involved in the audit?

You provide a set of claim input, claim response and query response files for an agreed-upon period.
Our compliance experts examine this data for issues that can prevent proper and timely reporting of:

• Acceptance of ongoing responsibility for medicals (ORM)
• Termination of ORM
• TPOC

We also look for:

• Errors in claim input file data
• CMS-identified errors and flags in claim response files
•  Consistency of your policies and procedures with CMS Section 111 reporting standards

You’ll receive an audit report and consultation. The report will identify actual or potential errors, omissions and inconsistencies and recommend corrective actions. You’re not left on your own! Tower collaborates with you during the audit and guides the implementation of process and policy changes. As with all our services, we answer your questions and consult with you every step of the way.

How does this help conditional payment resolutions?

If payers or their RREs fail to report ORM termination through Section 111 reporting, Medicare assumes the payer is still responsible for injury-related medical bills. The agency will either deny payment on these or pay them and seek reimbursement through the conditional payment process. The audit identifies TPOC/ORM/Section 111 reporting issues and shows you how to fix them to prevent unnecessary conditional payment demands.

Tower’s Section 111 Audit provides quick fixes and policy and process changes for long-term Section 111 reporting compliance assurance.

Next steps? Contact Hany Abdelsayed, our EVP of Strategic Services at
hany.abdelsayed@towermsa.com or 888.331.4941.