CMS Publishes Top 10 NGHP Section 111 Reporting Errors

by F. Fairchok

The Centers for Medicare & Medicaid Services (CMS) published an updated listing of the top 10 errors for NGHP Section 111 reporting on January 22, 2024. This update covers the period of July 1, 2023 through December 15, 2023.

In a change from previous reports, CMS has only included errors that will result in the claim being rejected with an SP disposition code and is not including any “soft edit” errors.

The two-page report contains Figure 1 – NGHP Reporting Error Codes as follows:

Also, included on the second page is a list of error descriptions in Table 1 – Error Code Descriptions as follows:

There is a discrepancy between the figure and table in that Figure 1 shows the last error to be CI04  (State of Venue) while Table 1 indicates it is CJ04 related to an invalid TPOC amount or format. Error CI04 relates to the State of Venue, but this is not a common error as state postal abbreviations have been one of the easier fields to populate since the inception of reporting. Also, as the previous error is CJ03, related to the TPOC, it is likely that the last error could also be related and would therefore be CJ04.

Understanding these errors is crucial, as they will result in the claim being rejected by CMS. If 20% of the claims in a quarterly claim file submission result in errors, the entire file is suspended and not processed. Responsible Reporting Entities should monitor their submissions for errors as a rejected claim or file could result in late reporting of ORM or TPOC, which increases the risk of Civil Money Penalties.

For questions regarding this article or how IMPAXX can help review your quarterly response files from CMS, please don’t hesitate to email us at [email protected]. If you are looking for further guidance on Section 111 reporting compliance, our experienced Medicare Secondary Payer Reporting services team can collaborate with you to customize the compliance experience to meet your unique needs and requirements.