Top 10 Section 111 Non-Group Health Plan Reporting Error Codes During Second Half of 2023

Written by: Kathy Bell

Last week, the Centers for Medicare & Medicaid Services (CMS) hosted a webinar addressing civil money penalties (CMPs) for noncompliant Section 111 reporting. As part of that webinar, CMS noted that a Responsible Reporting Entity’s (RRE) untimely Section 111 reporting due to errors in the claim file may still result in CMPs against the RRE. To better assist RREs in identifying where errors are most likely to occur, CMS has now issued the “Top 10 Section 111 Non-Group Health Plan Reporting Error Codes from July 1 – December 13, 2023,” available here. 

The following three error codes are, by far and away, the most frequent as illustrated by CMS’ published chart:

Error Code TN99 – Invalid TIN Record/Office Code – No matching, valid TIN was found.

Error Code CI05 – Invalid Diagnosis Code 1 – This may result from a missing valid ICD Code or could occur where the RRE inserts an invalid ICD code, likely due to spacing, decimal point, or other input issues.

Error Code SP49 – No Aux Occurs for Delete – No previously accepted record can be matched to the submitted delete. 

As an additional consideration, if there are more than 20% errors within a CMS claim file, CMS will reject the entire file potentially resulting in CMPs for late reporting of Total Payment Obligation to the Claimant (TPOC) and Ongoing Responsibility for Medicals (ORM) if the records are not corrected and re-reported.

Sanderson Firm Commentary:

If your claims organization frequently encounters these (or other) Section 111 reporting errors, Sanderson Firm is available for assistance. Our SandersonComply reporting solution provides primary payer clients with a purpose-built, user-friendly tool for accurate and timely Section 111 reporting compliance. SandersonComply also includes data pre-validation, EDI and API data integration, automated file submissions (and more), which streamlines an otherwise challenging and cumbersome Section 111 reporting process.

If you have any questions regarding CMS’ Top 10 reporting errors, would like to schedule a demo for SandersonComply, or have any other Section 111 reporting-related inquiries, please contact us.