Sanderson Firm Introduces Proprietary Medicare Section 111 Reporting Solution: SandersonComply

Bradenton, FL, December 6, 2023: Sanderson Firm PLLC, an industry-leading Medicare Secondary Payer (MSP) compliance firm servicing the insurance and legal communities nationwide, is proud to announce the launch of its proprietary Medicare Section 111 Reporting solution, SandersonComply.

Medicare Section 111 Reporting Services are not an entirely new service to Sanderson Firm. Since 2021, Sanderson Firm has provided Medicare Section 111 Reporting services for hundreds of Responsible Reporting Entities (RREs). Three (3) years later, due to rapid growth in demand in Section 111 Reporting Services from RREs which includes workers’ compensation, general liability, and no-fault insurance payers/plans, Sanderson Firm is looking forward to providing established Section 111 customers as well as future prospective Section 111 customers with enhanced capabilities with our newly branded proprietary Medicare Section 111 reporting solution, SandersonComply.

Sanderson Firm’s Medicare Secondary Payer and Section 111 Reporting services are unmatched in the industry. Sanderson Firm has garnered a reputation for stellar service and customization for all Section 111 needs. Included with the SandersonComply annual reporting fee for RREs is oversight of data, as well as a customized and consultative approach with each Section 111 Reporting client to ensure compliance with MSP and Section 111.

Legal Background & Requirements for Workers’ Compensation, General Liability, and No-Fault Primary Insurance Payers to Report Medicare Beneficiary Claims or Face up to $1000 per day/per claim.

Nearly two decades ago, Congress passed Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (“MMSEA” or “Section 111 reporting”), which requires primary payers to report certain claims information to the Centers for Medicare & Medicaid Services (“CMS”) for settlements, judgments, awards, or other payments involving Medicare beneficiaries. Section 111 reporting allows the federal government to better determine when it has “primary” versus “secondary” payer responsibility for a Medicare beneficiary’s medical expenses, and failure to properly report may result in civil monetary penalties of up to $1,000 per day, per claim (42 U.S.C. § 1395y(b)(8)(E)(i)).

Most recently, on October 11, 2023, CMS published its Final Rule specifying how and when CMS will impose a Civil Money Penalty (CMP) against a non-compliant primary payer. The Final Rule becomes effective on December 11, 2023, and it becomes applicable on October 11, 2024. To date, CMS has not issued a CMP against a non-compliant primary payer / Non-Group Health Plan (workers’ compensation, general liability, and no-fault insurance primary payers/plans). However, with a Final Rule now in place, CMS is poised to soon begin enforcing CMPs (estimated to be calculated at ~$42 million per calendar year as applied to 2022 Non-Group Health Plan reporting data).

Introducing SandersonComply

SandersonComply will provide primary payer clients with a purpose-built, user-friendly reporting solution for accurate and timely Section 111 reporting compliance.

With benefits including data pre-validation, EDI and API data integration, automated file submissions, and more, SandersonComply streamlines an otherwise challenging and cumbersome reporting process. SandersonComply leverages decades of MSP compliance experience and will highlight potential issues or missing data points to further ensure accurate reporting, providing primary payer clients with the ideal Section 111 reporting compliance solution.

“As CMS has ramped up its enforcement of Section 111 compliance and will soon be imposing Civil Money Penalties against primary workers’ compensation, general liability, and no-fault insurance payer/plans, we are enthused to introduce a solution to the MSP compliance market which will reliably improve reporting outcomes for our clients and reduce the possibility of penalties,” said Heather Sanderson, Chief Executive Officer.

Sanderson Firm’s Section 111 Expert and Department lead, Kathy Bell, CPCU, AIC, SCLA, CMSP said: “SandersonComply provides a flexible reporting solution to meet the needs of the client with personalized monitoring and insight of the data.”

To schedule a demo or for more information about SandersonComply, please contact us

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CMS Workers’ Compensation Medicare Set-Aside (WCMSA) Statistics: 2023 Update and Civil Money Penalty Webinar Announcement

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While Medicare Section 111 Reporting Civil Money Penalties May Not Occur Until Late 2025, Exposure Remains for Unreported Historical Claims/Settlements