SCHIP section 111 reporting: Everything you need to know to avoid penalties

If you're responsible for SCHIP Section 111 reporting, you know it can be a complex, detailed process with significant compliance implications. Here, Suzanne Jordan, Broadspire's 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-subscribe to her YouTube posts here 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's a one-year window before penalties kick in, but don't get too comfortable. October 11, 2025, is when warning notices will start to arrive if reporting deadlines aren't 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:

• 1-2 years late: $357 per day
• 2-3 years late: $714 per day
• More than 3 years: $1,428 per day

The maximum penalty cap is a hefty $521,220, so it's essential to stay on top of deadlines.

What does "late" reporting mean in this context?

According to CMS, a claim is considered "late" 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're the one managing claims, you're 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're dedicated to keeping clients compliant and avoiding any penalties.

For more updates, keep an eye on Suzanne Jordan's "MSP In A Minute" 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's 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't 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's 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 ensures compliance and keeps all relevant parties up to date.

What happens if a claimant isn't a medicare beneficiary initially?

If a claimant isn't a Medicare beneficiary at the first inquiry, we continue to check monthly until their Medicare status changes. This ongoing process helps to ensures we're always up to date on each claimant's eligibility.

When is ORM (ongoing responsibility for medicals) considered terminated?

ORM refers to the RRE's obligation to cover an injured worker's 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's claim adjuster submits the ORM termination date to CMS.

What if a claimant requests a "closure letter" on behalf of medicare?

If an injured worker reaches out, asking for a "closure letter" due to Medicare's instructions, direct them to email us at [email protected]. Include the claimant's 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 [email protected] or contact Suzanne Jordan, our Medicare Compliance Director, directly at [email protected].

Staying compliant can feel overwhelming, but with expert support from Broadspire, you can keep your focus on what matters most-supporting your clients and managing claims efficiently.

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