Section 111 Audit

Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) added mandatory reporting requirements for insurer and self-insured payers to report Medicare beneficiary claimants.  A claim must be reported to Medicare when a settlement, judgment, award or other payment is made or when the payer accepts or terminates responsibility for ongoing medicals.

Compliance with these requirements is maintained by the imposition of penalties for untimely reporting by the Centers for Medicare and Medicaid Services (CMS). Such penalties can easily reach tens of thousands of dollars even if one claim is reported untimely or is otherwise considered untimely by, for example, a failure to report a diagnosis code. Besides penalties, Section 111 reporting errors and omissions can result in unnecessary Medicare conditional payment demands.

Tower’s Section 111 Audit identifies errors, inconsistencies and omissions in reporting and provides a roadmap for corrective actions.  Tower collaborates with you during the audit to make corrections and guide the implementation of needed process and policy changes.  We position you to avoid potential Section 111 penalties and eliminate unnecessary conditional payment demands.

Audit Parameters

  • Tower’s Section 111 Audit will review:
  • Current Section 111 reporting policies and procedures
  • Overall reporting errors
  • Percentage of reporting errors versus total reported claims
  • Proper and timely ORM termination
  • Inconsistencies and omissions in reported data
  • Potential missed claims reporting

Audit Report

The audit report provides recommendations for error correction and proposals for internal policy and process changes.  We will walk you through the report, answer any questions, and then continue consultation throughout the corrective action process.