Section 111 mandatory reporting provisions for Non-Group Health Plans (NGHP) were the topic of CMS’ town hall teleconference on July 28, 2015. CMS speakers also highlighted several of CMS’ recent alerts involving upcoming transitions of portions of the NGHP recovery workloads from the Coordination of Benefits and Recovery (COB&R) program to the Commercial Repayment Center (CRC) in claims involving direct recovery from applicable plans as well as CMS’ transition from ICD9 to ICD10 codes. Although the CRC transition is expected to occur in October of 2015, CMS will require the use of ICD10 codes in Section 111 reporting as of October 1, 2015.
The need for the accuracy in the reported ICD10 codes was stressed by CMS representatives. They warned that failure to provide accurate codes may lead to issues with treatment coverage as well as flawed conditional payment recovery attempts. Since the ICD10 system provides far more diagnosis codes and updated terminology when compared to the outdated ICD9 system, providers should be able to be much more specific in their documentation of the treatment. In addition, CMS advised that after October 1, 2015, they will not accept a combination of ICD9 codes and ICD10 codes when reporting new claims.
CMS speakers also addressed the importance of maintaining updated contact information and complying with CMS’ recertification requirements for RREs and agents in order to prevent any possible noncompliance issues. Changes to the matching criteria when using partial Social Security Numbers (SSN) were reviewed. Given the high number of false positives in the partial SSN query process, CMS will now require a match of four out of four criteria. Modifications to file naming conventions and TIN Reference Files were also noted.
Additional information on these points may be found in the updated Section 111 NGHP User Guide that was last modified on July 13, 2015. We will continue to keep you advised of further developments.