Medicare issued three alerts in June 2012 about new reporting thresholds

Liability (TPOCs)

The 1 July 2012 threshold now requires insurers and self-insured entities to report liability settlements over $25,000 under Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA Section 111).  Any settlement over $25,000 after 1 July, must be reported next quarter (e.g, after 1 October 2012). CMS extended the $5,000 threshold for workers' compensation to 1 October 2012 and indefinitely extended the ORM threshold. Other thresholds for reporting a settlement date were moved back one month while the first time to report remains the same.  CMS matches their $300 settlement recovery limit by lowering the ultimate threshold to $300.

The “Total Payment Obligation to the Claimant (TPOC) Dollar Thresholds for Certain Liability Insurance (Including Self-Insurance)” includes:

  • Settlements over $5,000 made after 1 October 2012 report after 1 January 2013.
  • Settlements over $2,000 made after 1 October 2013 report after 1 January 2014.
  • Settlements over $300  made after 1 October 2014 report after 1 January 2015.

The move to one quarter earlier was to correct a typographical error in the version 3.3 of the NGHP User Guide that did not allow for reports to be filed at the beginning of the year at the reduced threshold.  We at Piatt Consulting were hopeful that CMS would retain the $5,000 limit as providing CMS with a good “Return On Investment”, but at the moment, CMS seems inclined to match their new $300 recovery threshold, which is their “break even” point.

Workers’ Compensation (TPOCs)

To recover from a typological error that left an uncertain threshold for 2013, CMS has extended today’s threshold of $5,000 for settlements to 1 October 2013 and pulled back the $2,000 threshold to settlements after 1 October 2013.  They also reduced the last threshold from $600 to $300 and pulled it back one quarter to  1 October 2014.

The “Mandatory Total Payment Obligation to the Claimant (TPOC) Dollar Thresholds for Certain Liability Insurance (Including Self-Insurance)” includes:

  • Settlements over $5,000 made after 1 October 2010 report after 1 January 2011
  • Settlements over $2,000 made after 1 October 2013 report after 1 January 2014.
  • Settlements over $300  made after 1 October 2014 report after 1 January 2015.

Workers’ Compensation (ORM)

CMS has indefinitely extended the December 31, 2012 deadline