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Final Rule on Medicare Reporting Civil Monetary Penalties (CMPs) Announced

On October 10, 2023, Medicare published an Alert to the Final Rule outlining Centers for Medicare & Medicaid Services (CMS) guidance around Civil Monetary Penalties (CMPs).

CMS has finalized its rule specifying how and when CMS will calculate and impose civil money penalties (CMPs) when group health plan (GHP) and non-group health plan (NGHP) responsible reporting entities (RREs) fail to meet their Medicare Secondary Payer (MSP) reporting obligations.

The text of the final rule can be found and reviewed in its entirety in the Federal Register, which can be found at

This rule is effective as of 60 days following the date of publication (December 11, 2023), but is only applicable one year after publication (October 10, 2024). RREs are expected to be compliant with their Section 111 Mandatory Insurer Reporting requirements no later than October 10, 2024, or they may be eligible for a CMP.

Do you have questions about your responsibilities for compliance? Please let us know if you would like to discuss your MMSEA Section 111 reporting needs with an experienced team.

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