New Section 111 TPOC Alert Issued By CMS

by B. Smith

CMS issued a new alert regarding the requirement to complete the Funding Delayed Beyond TPOC Start Date field in applicable situations. Specifically, the alert is a reminder that if funding is delayed after the settlement date and the TPOC Date in Field 80 has been reported, Responsible Reporting Entities (RREs) should also provide the actual or estimated date of funding in Field 82: Funding Delayed Beyond TPOC Start Date. CMS notes that when the TPOC Date and TPOC Amount are reported, the recovery process commences and failing to report the delay in funding can have a negative impact on the beneficiary. In addition, CMS states that completion of this field in applicable cases is also “used to ensure that an RRE is not found non-compliant with the Section 111 timelines reporting requirements when a settlement has been made, but the final payment amount has not yet been determined or dispersed.”

As we move closer to the potential implementation of Section 111 Civil Monetary Penalties, CMS has continued to issue alerts and hold Town Halls to stress the importance of proper reporting. Now is the time to assess the health of your Section 111 program. CMS may be accepting the data you are reporting, however, if dates, amounts and diagnosis codes are incorrect, you are open to potential penalties in the future and additional exposure for conditional payments now. If you have questions regarding where to begin in this process, please contact the NuQuest Settlement Consultant Team at [email protected].