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CMS PROPOSED RULEMAKING MMSEA Section 111 Mandatory NGHP Insurer Reporting

Just last week, we advised of a Notice of Proposed Rulemaking from the Center for Medicare and Medicaid Services (CMS) that could usher in the beginning of the Liability Medicare Set Aside (LMSA) process. Now, CMS has announced yet another proposed rulemaking regarding MMSEA Section 111 Mandatory Non-Group Health Plan (NGHP) insurer reporting called “Civil Monetary Penalties and Medicare Secondary Payer Requirements.” The reporting process requires that Responsible Reporting Entities and/ or their reporting agents, report all claims involving Medicare beneficiaries to CMS on a quarterly basis. Five years ago, CMS issued the same proposed rulemaking and solicited thirty-four comments during t

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