Restrictions on Quarterly File Submissions Lifted for NGHP RREs

On May 1, 2012, CMS issued an Alert announcing that RREs would now be permitted to submit additional MMSEA Section 111 Claim Input Files within the same quarter.  Previously, RREs were restricted to submitting only one file per quarter. The lifting of this restriction will allow RREs the opportunity to provide updated claims data to CMS more expeditiously. For example, claim records with ORM may be closed out without the need to wait until the following quarter, allowing CMS to more consistently obtain the information needed to properly coordinate benefits. Within the Alert, CMS noted that two limitations apply to this change:

  • A subsequent file submission will not be processed until the prior one has been completed and a response file generated.  NGHP RREs should not submit a subsequent file until they have received the response to the previous file submission.
  • Without exception, NGHP RREs will be limited to only one file submission every fourteen days.

RREs are still expected and required to adhere to the standard quarterly file submissions according to their assigned file submission periods.  There is no requirement to submit more than one file per quarter.  CMS stated that the contents of this Alert will be incorporated into the next version of the User Guide. 

PMSI applauds this Alert from CMS and believes that the lifting of this restriction will allow for better compliance by RREs with MMSEA reporting requirements. Better compliance can decrease the potential for fines against RREs if they can report a missed claim or correct a submission as early as fourteen days. Additionally, more accurate and frequent reporting can result in a better coordination of benefits decreasing the instances of beneficiaries being denied Medicare coverage.  For more information regarding denial of Medicare coverage please see PMSI’s previous blogs dated August 5, 2011 and November 22, 2011.

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