If you鈥檙e responsible for SCHIP Section 111 reporting, you know it can be a complex, detailed process with significant compliance implications. Here, Suzanne Jordan, Broadspire鈥檚 Medicare Compliance Director, answers some of the most frequently asked questions to help you stay on top of your responsibilities and avoid costly penalties. Don't miss Suzanne's expert insights鈥攕ubscribe to her YouTube posts to stay informed and compliant!
When do penalties for non-compliance begin?
Starting on October 11, 2024, CMS began actively monitoring for late reporting. There鈥檚 a one-year window before penalties kick in, but don鈥檛 get too comfortable. October 11, 2025, is when warning notices will start to arrive if reporting deadlines aren鈥檛 met. From there, the penalties escalate quickly based on the number of years the report is overdue.
How significant are the penalties for late reporting?
The penalties can add up fast, and they increase over time:
- 1鈥�2 years late: $357 per day
- 2鈥�3 years late: $714 per day
- More than 3 years: $1,428 per day
The maximum penalty cap is a hefty $521,220, so it鈥檚 essential to stay on top of deadlines.
What does 鈥渓ate鈥� reporting mean in this context?
According to CMS, a claim is considered 鈥渓ate鈥� if the Ongoing Responsibility for Medicals (ORM) or Total Payment Obligation to Claimant (TPOC) is reported a year or more after the initial reporting requirement. Simply put, waiting too long to report can result in penalties.
What are my responsibilities as an RRE?
As a Responsible Reporting Entity (RRE), you need to register and report any claims involving a Medicare beneficiary on the CMS website. This means if you鈥檙e the one managing claims, you鈥檙e also the one responsible for compliance.
What is Broadspire doing to protect clients from penalties?
Broadspire is proactive about SCHIP compliance. We have a specialized team with over 12 years of experience in this area. Our SCHIP reporting environment is built to minimize human error by incorporating automation alongside mandatory training for our claim adjusters. With these measures, we鈥檙e dedicated to keeping clients compliant and avoiding any penalties.
For more updates, keep an eye on Suzanne Jordan鈥檚 鈥淢SP In A Minute鈥� vlog, where she covers compliance topics in bite-sized sessions.
How do we verify if an injured worker is a medicare beneficiary?
We regularly send data to CMS to verify the Medicare status of injured workers. When a claim meets all requirements, it鈥檚 flagged for Section 111 reporting. This process helps us ensure that all claims are handled appropriately and reported on time.
What information is required for medicare eligibility verification?
To confirm if someone is a Medicare beneficiary, we need to submit five key data points: First Name, Last Name, Social Security Number (SSN) or Medicare Beneficiary Identifier (MBI), Date of Birth, and Gender.
What if the injured worker won鈥檛 provide their SSN?
If an injured worker declines to share their SSN, we follow documented attempts to collect this information. This includes two written and one electronic attempt (via email, phone, or fax), all recorded in our system using CMS鈥檚 Safe Harbor Form.
How frequently does Broadspire report claim information to CMS?
Broadspire reports claim information quarterly to CMS on your behalf. This regular reporting helps to聽ensures compliance and keeps all relevant parties up to date.
What happens if a claimant isn鈥檛 a medicare beneficiary initially?
If a claimant isn鈥檛 a Medicare beneficiary at the first inquiry, we continue to check monthly until their Medicare status changes. This ongoing process helps to聽ensures we鈥檙e always up to date on each claimant鈥檚 eligibility.
When is ORM (ongoing responsibility for medicals) considered terminated?
ORM refers to the RRE鈥檚 obligation to cover an injured worker鈥檚 medical costs. Broadspire terminates ORM when this responsibility ends, using automation or following CMS guidelines as state laws allow. After a claim is settled, Broadspire鈥檚 claim adjuster submits the ORM termination date to CMS.
What if a claimant requests a 鈥渃losure letter鈥� on behalf of medicare?
If an injured worker reaches out, asking for a 鈥渃losure letter鈥� due to Medicare鈥檚 instructions, direct them to email us at schip@choosebroadspire.com. Include the claimant鈥檚 contact details, and our team will handle it from there.
Have more questions?
If you have additional questions about SCHIP reporting, feel free to reach out to our SCHIP Compliance team at schip@choosebroadspire.com or contact Suzanne Jordan, our Medicare Compliance Director, directly at Suzanne.Jordan@choosebroadspire.com.
Staying compliant can feel overwhelming, but with expert support from Broadspire, you can keep your focus on what matters most鈥攕upporting your clients and managing claims efficiently.
