CMS Issues New Guidance on MMSEA Section 111 Reporting Requirements: Time for Compliance Is Extended

Late last week, CMS released Version 3.0 of its User Guide, a manual that serves as the road map for compliance with the mandatory reporting requirements set forth in Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007. Most notable among the Version 3.0 updates is the change to the timelines applicable to reporting entities. CMS delayed the initial file submission deadline, originally scheduled for the second quarter of 2010, to the first quarter of 2011. Entities subject to the Section 111 reporting requirements must include in their initial reports all settlements with Medicare beneficiaries that occur on or after October 1, 2010, and claims for which ongoing responsibility for medicals exists as of January 1, 2010.

This timeline change will provide liability insurers, including self-insurers, additional time to prepare for implementation of the Section 111 reporting requirements. For those entities on target with the previously provided deadlines, the coming months can be used to refine internal data collection systems and perfect information exchange methods with CMS. Entities in the infancy stages of compliance or those that have not yet initiated compliance efforts should take advantage of this extension and act now to learn and implement the Section 111 requirements.