CMS issued an Alert on November 15, 2016, concerning 2017 Recovery Thresholds. On December 12, 2016, it issued another Alert regarding 2017 Reporting Thresholds. CMS also updated its NGHP User Guide on January 3, 2017.
The effect of the Alerts:
Reporting Threshold: $750.00 for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation payments.
- Liability: If the Total Payment Obligation to the Claimant (“TPOC”) date is 1/1/2017 (or after) and the payment exceeds $750.00, the payment must be Section 111 reported.
- No-Fault: If the TPOC date is 10/1/2016 (or after) and the payment exceeds $750.00, the payment must be Section 111 reported.
- Workers’ Compensation: If the TPOC date is 10/1/2016 (or after) and the payment exceeds $750.00, the payment must be Section 111 reported.
Recovery Threshold: Effective January 1, 2017, the recovery threshold is $750.00 for physical trauma-based liability payments. This means that CMS may assert a right to recovery/reimbursement if the payment exceeds $750.00. However, there is no monetary threshold for recovery/ reimbursement in ingestion, implantation or exposure cases. CMS reserves the right to assert a recovery claim regardless of the amount of the payment in ingestion, implantation and/or exposure cases.
The recovery threshold on workers’ compensation and no-fault payments remains $750.00 as long as the workers’ compensation or no fault entity does not otherwise have ongoing responsibility for medicals.