MMSEA Section 111 Reporting – Postponed

Medicare Set-Aside Blog on February 18, 2010
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From CMS website

February 16, 2010

CMS advises all NGHP RREs that the date for first production NGHP Input Files is changed from April 1, 2010 to January 1, 2011, effective immediately.

NGHP File data exchange testing will continue.  All NGHP RREs should now be registered with the COBC, and either in or preparing for file testing status.  NGHP file data exchange testing may continue during 2010, as needed.
All NGHP file data exchange testing will be completed by December 31, 2010.  NGHP RREs that have completed file data exchange testing at any time are encouraged to proceed to production file data exchange status.

During the week of February 22, on this Website CMS will post the next version of the “Section 111 NGHP User Guide” and a number of Alerts relating to particular NGHP policy issues.

Also during the week of February 22, on this Website CMS will post an alert for NGHP RREs describing the steps those RREs can take to assure their ongoing compliance with the Section 111 reporting requirements.

MEDVAL Comments: This news comes as no surprise given the technical difficulties clients have been facing during the initial testing and production phases. I think CMS may have bitten off a little more than they can chew given the magnitude of the RRE universe and the complexity of gathering required fields. With so many unresolved issues and no guidance forth coming from CMS, the only logical step was to postpone live reporting.  This should give the industry more time to decide how to best comply with the requirement and give clients more time to consider their reporting agency relationships.

MEDVAL recommends ISO Claim Search as a reporting agent for those clients that do not develop an internal capability.