Revised CMS TPOC TimelineCenters for Medicare & Medicaid Services (CMS) announced September 30 that it has revised the reporting implementation timeline for certain liability insurance (including self-insurance) for Total Payment Obligation to the Claimant (TPOC) settlements, judgments, awards and other payments.

The new Section 111 reporting schedule is based on the TPOC amount.

Below is the content of the Alert. For a copy of the official CMS alert announcing the new reporting dates, go to CMS 9-30-11 Alert.

Office of Financial Management/Financial Services Group
September 30, 2011

Medicare Secondary Payer Mandatory Reporting Provisions in
Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA)
(See 42 U.S.C. 1395y(b)(7)&(b)(8))


Revised Implementation Timeline for Certain Liability Insurance
(Including Self-Insurance) Total Payment Obligation to the Claimant (TPOC)
Settlements, Judgments, Awards or Other Payments

The Centers for Medicare & Medicaid Services (CMS) has delayed Section 111 reporting for certain liability insurance (including self-insurance) TPOC settlements, judgments, awards, or other payments. The implementation date for reporting will be based on the TPOC amount. Below is a schedule of the new dates.

The CMS has not changed any other MMSEA Section 111 implementation dates. See the applicable MMSEA Section 111 User Guide. In addition, other relevant information, including explanations of TPOC, ORM, and a Responsible Reporting Entity, can be found in the User Guide. (Note: This delay is optional).

The content of this ALERT supersedes the content of the existing User Guide (Version 3.2) and will be incorporated into the next version of the User Guide. After full implementation of the Section 111 reporting requirements, CMS will use the normal notice of proposed rulemaking process for establishing any penalties.

TPOC Amount TPOC Date On or After Section 111 Reporting Required in the Quarter Beginning
TPOCs over $100,000 October 1, 2011 January 1, 2012
TPOCs over $50,000 April 1, 2012 July 1, 2012
TPOCs over $25,000 July 1, 2012 October 1, 2012
All TPOCs over min. threshold October 1, 2012 January 1, 2013


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