CMS Updates Unified Agenda Regarding Date for Civil Money Penalty Provisions for MSP Reporting Requirements

CMS, Mandatory Insurer Reporting, MSP News on August 12, 2019
Posted by Jean S. Goldstein, JD

Last week, we provided an update that the Centers for Medicare and Medicaid Services (CMS) updated the Unified Agenda as related to the proposed rulemaking for guidance regarding how to satisfying Medicare Secondary Payer (MSP) obligations. The Unified Agenda was also recently updated with respect to the proposed rule regarding civil money penalties for MSP reporting requirements. You may recall in December, we reported that CMS added a notice of a proposed rule involving MSP reporting, which would address obsolete regulations and propose criteria and practices for which monetary penalties would and would not be imposed under the SMART Act.  The update, while very minor, indicates that the due date on the notice is now October 2019, as with the updated MSP obligations notice.  However, unlike the MSP obligations notice, this notice is still not documented as the potential rule being major or economically significant. 

There is certainly much that will need to be addressed by a proposed rule involving civil monetary penalty provisions for MSP reporting, and we will be closely monitoring the Unified Agenda for any further developments.   We will be sure to update our readers on any progress on either of the proposed rules.