CMS Has Finalized its Final Rule on Section 111 Reporting Civil Monetary Penalties

Authored by Brendon Desouza Esq.

Today, the Centers for Medicare & Medicaid Services (CMS) provided notice that it has finalized its rule for calculating and imposing Civil Monetary Penalties (CMPs) against Responsible Reporting Entities (RREs) that fail to properly report Medicare beneficiary claims pursuant to Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007. The text of the notice is located here.

The Final Rule currently remains unpublished in the Federal Register, but it is scheduled to be published tomorrow, October 11, 2023. The text of the soon-to-be-published Final Rule is located here.

Of note, the Final Rule will become effective on December 11, 2023, and it becomes applicable on October 10, 2024. Therefore, RREs will be subject to CMPs if they are not compliant with Section 111 reporting obligations by October 10, 2024.

In addition to the analysis provided by Sanderson Firm, you can also gain valuable insights from experts in the field. Heather Sanderson, Kathy Bell, and Brendon De Souza will be part of a webinar hosted by Sanderson Firm to discuss the Final Rule on Monday, October 16th at 1:00 PM EST.. Register here for Sanderson Firm’s webinar regarding the Final Rule.

If not already subscribed, please subscribe for immediate updates. If your organization has any questions about this notice or the Final Rule, please contact us

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Are All Arrows Pointing Towards Imminent Civil Monetary Penalties for Medicare Section 111 Reporting?