Cases & Points Blog

CMS Issues New Section 111 NGHP User Guide and PAID Act Technical Alert

CMS has been very busy this month.  In addition to the webinar scheduled for June 23, 2021 to discuss the Provide Accurate Information Directly (PAID) Act.  CMS has now issued a new NGHP User Guide and a PAID Act technical Alert.  The User Guide and the Alert contain significant substantive and technical changes regarding ORM […]

CMS Hosting PAID Act Webinar

The Centers for Medicare and Medicaid Services (CMS) announced today that they will be hosting a PAID Act webinar on June 23, 2021 at 1 PM ET.  This alert is located on the CMS NGHP website What New page and can be found here.  CMS states that the webinar will cover “what the PAID Act […]

Going Down the Rabbit Hole Post Settlement: What Can Medicare Do?

By P. Czuprynski The Medicare Secondary Payer Act (MSP) identifies Medicare is supposed to be second in line for payment if there is a non-group health plan that covers a certain date of incident or claimed medical expenses (i.e. workers’ compensation, liability or no-fault claim). What this means is if Medicare made payment, but the […]

CMS Releases Updated WCMSA Reference Guide 3.3

CMS has released a new version of the Workers’ Compensation Medicare Set-Aside (WCMSA) Reference Guide, 3.3, COBR-Q2-2021-v3.3 dated April 19, 2021. The new Guide includes additional language regarding the calculation of the seed money for structured settlements. When a structured WCMSA is utilized by the parties, in addition to annual payments, a calculation of the […]

Updated Section 111 NGHP Model Language

CMS has released an updated Section 111 Model Language form to assist Responsible Reporting Entities (RREs) in obtaining critical information needed to determine claimants’ Medicare eligibility status.

CMS BCRC and CRC NGHP Town Hall Updates

On April 1, 2021, CMS held its scheduled Town Hall with the Benefits Coordination & Recovery (BCRC) and Commercial Repayment Center (CRC) for Non-Group Health Plans (NGHP).  Although parts of the Town Hall included information that was already disseminated by CMS in the past, there were some specific highlights as noted below. Partial Resolution of […]

CMS Updates Life Tables for WCMSAs

Beginning March 27, 2021, CMS will convert to  the CDC’s “Table 1: Life Table for the total population: United States, 2018” for all Workers’ Compensation Medicare Set-Aside life expectancy calculations.  A link to the 2018 Life Tables can be found here.  The life tables are used by CMS to calculate the length of medical treatment […]

Interplay: Section 111 Reporting and Conditional Payments

The Medicare Secondary Payer Act (MSP) and Medicare’s Section 111 User Guide require a carrier/self-insured to report to Medicare, when appropriate: Ongoing Responsibility for Medical (ORM); OR Settlement, judgement, award or other payment These requirements allow Medicare to perform three actions when presented with a medical payment that may be associated with a workers’ compensation, […]

CMS NGHP User Guide 6.2

In less than four months, CMS has issued three revised versions of the Non-Group Health Plan (NGHP) Section 111 User Guide.  The most recent version, Guide 6.2, includes some of the following updates: In Chapter IV, Section 6.7.1 of the Guide, CMS notes that those Responsible Report Entities (RREs) who can identify a future Ongoing […]

CMS Amended Review

by Nancy Heidrich January 22, 2021 The Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) Reference Guide Version 2.6 published on July 10, 2017 introduced the CMS Amended Review as another re-review option. The Amended Review allows the parties a one-time request for re-review in the form of a new submission. To be accepted for the amended […]