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CMS Publishes Top 10 NGHP Section 111 Reporting Errors

July 24, 2024
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Hand typing on laptop on a desk next to reports with blue graphics and alongside a pen, a glass with water, and eyeglasses.

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 July 19, 2024. This update covers the period of January 1, 2024, through June 15, 2024.

CMS modified this report in January 2024 to only include errors that will result in the claim being rejected with an SP disposition code and continues to exclude 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:

While the report states that it only includes hard errors that will result in record rejections, CI03 for an invalid alleged cause of injury is included. However, the NGHP User Guide still states that the alleged cause of injury code is optional and that the CI03 error code will not result in record rejection. IMPAXX believes the Top 10 list is in error for including CI03 but, in an abundance of caution, has reached out to clarify if this error is now a hard error.

Also notable on the updated report is that the new number one error code is CI05 for invalid ICD Diagnosis Code #1. The TN99 error for invalid TIN/Office Code moved from the top error on the last report to the second slot in this update.

It is important to remember that hard errors 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 will be suspended and not processed. Responsible Reporting Entities (RREs) should monitor their submissions for errors as a rejected claim or file could result in late reporting of Ongoing Responsibility for Medical (ORM) or Total Payment Obligation to Claimant (TPOC) representing a risk for Civil Money Penalties.

For questions regarding this article, and/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. Contact us today to learn more.