October 30, 2023 — On October 11, 2023, the Centers for Medicare and Medicaid Services (CMS) published its Final Rule addressing when and how it would impose a Civil Monetary Penalty (CMP), of up to $1,000/day per claim, upon a Responsible Reporting Entity (RRE) for non-compliance with Mandatory Insurer Reporting (MIR) requirements.

The official Final Rule significantly simplified the prior CMS proposed rules by defining untimely reporting of TPOC and ORM as the only basis for non-compliance to incur CMP's.

The Final Rule is considered effective on December 11, 2023. However, the provisions within the Final Rule are not applicable until October 11, 2024.

Gallagher Bassett is prepared for this rule change and no immediate action is required from our clients. We will keep you informed as CMS implements the provision in the Final Rule.

Should you have any questions, please do not hesitate to contact your Client Services Manager, or click here to download our Medicare Compliance Alert overview.

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