Top 10 Section 111 Non-Group Health Plan (NGHP) Reporting Error Codes from January 1 – June 15, 2024

Written By: Kathy Bell

The Centers for Medicare & Medicaid Services (CMS) has posted the list of the Top 10 Section 111 Non-Group Health Plan (NGHP) reporting errors from January – June 2024, available here.

Five (5) of the top ten (10) reporting errors are related to missing or invalid Internal Classification of Diseases (ICD) codes, which are reported by Responsible Reporting Entities (RREs) to communicate specific injury-related information to CMS. Notably, error code CI05 (Diagnosis Code 1) has nearly doubled in frequency as compared to last year’s data, available here. The improper reporting of ICD codes may significantly affect the conditional payment recovery efforts by CMS and the success of resolving conditional payments.  In addition to CMPs, failure to report accurate claim information timely can also result in Medicare beneficiary benefit coordination issues.

Sanderson Firm Commentary:

Section 111 civil money penalties become applicable on October 11, 2024. CMS’ 2024 data is significant because claim records with certain reporting errors (e.g., “hard errors” as noted in CMS’ 2023 and 2024 chart) will cause the record to be rejected by CMS. If the record is rejected and the RRE does not timely correct the record, this will result in late reporting thus subjecting the RRE to civil money penalty exposure. If your organization encounters such reporting errors, we highly recommend that such errors be corrected as soon as possible. Ultimately, a single untimely reported Medicare beneficiary record could result in a civil money penalty in excess of $365,000 as adjusted for inflation under 45 CFR part 102.

Sanderson Firm’s reporting solution, SandersonComply, provides RREs with a reporting tool for accurate and timely Section 111 reporting compliance. In addition to SandersonComply providing data pre-validation, Sanderson Firm provides data oversight and monthly monitoring of reporting errors to assist with timely and accurate reporting of claim data.

If you have any questions regarding CMS’ Top 10 reporting errors, would like to schedule a demo for SandersonComply, or have any other Medicare compliance inquiries, please contact us.