CMS Relays Important Information Regarding Section 111

Recently, the Centers for Medicare and Medicaid Services (CMS) held a webinar to discuss Section 111 Non-Group Health Plan compliance tips, common errors, and best practices. Please continue reading and reach out to the seasoned team here at MSA Meds to learn more about Section 111 and how we can assist you. Here are some of the questions you may have:

What settlements should be reported as a Total Payment Obligation to Claimant?

In Section 111, the only settlement that may be reported as a Total Payment Obligation to Claimant (TPOC) is one that includes medical benefits. Once TPOC is reported, it is required to include the following:

  • Both Medicare-covered and non-covered medical expenses
  • Attorney fees
  • MSA totals or non-CMS-approved allocations
  • Indemnity
  • Settlement advances
  • Property damages
  • Payout totals for annuities

What settlements should not be reported as a Total Payment Obligation to Claimant?

Settlements that mustn’t be reported as a Total Payment Obligation to Claimant are as follows:

  • Settlements solely including indemnity payments
  • In claims with histories of indemnity-only settlements and subsequent settlements closing out medical benefits, the initial indemnity-only settlement should not be included in TPOC

What should I do if a settlement closes for one or more condition but leaves others open?

When a settlement closes for one or more medical condition but remains open for others, the responsible reporting entity is required to use a two-step process to disclose as much in Section 111 reporting.

What are some of the most common error codes in regard to Section 111?

According to the Centers for Medicare and Medicaid Services, some of the most common error codes include inaccurate representative phone numbers causing soft errors and invalid ICD codes. To avoid this mistake, you should always enter ICD codes without decimals and ensure you correct all errors before the next quarterly file submission period.

For further questions regarding Section 111, please do not hesitate to contact MSA Meds today.