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Policy Guys Podcast - Episode 22: CMS final rule on civil monetary penalties for untimely reporting

December 7, 2023 · Public Policy & Regulatory Affairs Team

In this episode, the Policy Guys invite Michael Flower, Optum Associate General Counsel and resident expert on Medicare Set-asides, to help explain the latest CMS Section 111 rule changes and their implications for responsible reporting entities (RREs).

The discussion focuses on the stringent reporting requirements for RREs (including workers’ comp, liability and no-fault insurers), as well as the stiff penalties and fines for RREs that fail to meet those requirements.

RREs need not panic, though. Michael explains that the new rule won’t take effect until October 2024 and that CMS will start with claims reported one year after that instead of taking a retrospective approach.


Policy Guys Podcast