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CMS Releases New NGHP Section 111 Policy Alert

CMS releases updated Section 111 Model Language document

04/20/21 The Centers for Medicare and Medicaid Services has released an updated PDF version) for RREs to use as part of their efforts to obtain certain data points, including a claimant s social security number or Medicare number, to assist in determining his or her Medicare beneficiary status. While CMS does not require RREs to use this Model Language document, in practice, many RREs utilize this document as part of their Section 111 data collection activities. CMS s revised Model Language document dated March 10, 2021 updates the agency s prior version dated April 30, 2018. Overall, the updated Model Language document make various minor and non-substantive changes to the previous version.

CMS Releases Updated Section 111 Model Language Document

04/19/21 The Centers for Medicare and Medicaid Services has released an updated PDF version) for RREs to use as part of their efforts to obtain certain data points, including a claimant s social security number or Medicare number, to assist in determining his or her Medicare beneficiary status. While CMS does not require RREs to use this Model Language document, in practice, many RREs utilize this document as part of their Section 111 data collection activities. CMS s revised Model Language document dated March 10, 2021 updates the agency s prior version dated April 30, 2018. Overall, the updated Model Language document make various minor and non-substantive changes to the previous version.

CMS holds BCRC and CRC NGHP Town Hall session

04/07/21 Shawn Johnson and Jeremy Farquhar On April 1st, the Centers for Medicare and Medicare Services (CMS) held what it billed as a Benefits Coordination & Recovery (BCRC) and Commercial Repayment Center (CRC) non-group health plan (NGHP) Town Hall call. Joining CMS on this call were representatives from the BCRC and CRC. CMS s notice for this event indicated that this session was set to “discuss common NGHP topics” regarding Section 111 reporting and NGHP recovery issues. As part of this 75-minute event, CMS touched on several different topics, including the interplay between the BCRC and CRC, several unique Section 111 reporting situations, and the conditional payment appeals process. The majority of the call consisted of questions from the attendees.

PAID Act - Current Status and FAQs

03/12/21 Mark Popolizio, Kate Riordan, Jeremy Farquhar A major Medicare secondary payer (MSP) watch-list item for 2021 continues to be how and when CMS will implement the Provide Accurate Information Directly (PAID) Act. Signed into law on December 11, 2020, the PAID Act will make changes to CMS s Section 111 Query Process. In general, under the PAID Act, CMS will be required to provide RREs with information regarding a claimant s Medicare Part C (Medicare Advantage) and Medicare Part D (prescription drug) enrollment status through the Section 111 Query Process. At this time, the industry is waiting for CMS to release its PAID Act implementation plan, which will require yet to be released technical updates to its Section 111 Query Process. Thus, until CMS provides more information, RREs remain in a holding pattern regarding what technical updates may be necessary.

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