As Medicare moves into its first wave of Section 111 reporting audits, ECS is proud to announce services designed to support Responsible Reporting Entities (RREs) navigating the Civil Money Penalty (CMP) appeal process.
This industry has long discussed the looming possibility of monetary consequences up to $1,000 per day per claim. Now, CMS has made it known that enforcement is no longer theoretical. Beginning this quarter, CMPs will be imposed due to the failure to timely report settlements and ongoing responsibility for medicals to the Centers for Medicare & Medicaid Services (CMS). With audits commencing, exposure is real, and the financial and operational effects can be significant.
Regulations require CMS to randomly select 250 records for audit to evaluate reporting compliance, with the first audit occurring this month, February 2026. Initial notices identifying potential non-compliant records are expected as early as March. When a possible CMP is identified, the appeal process is both time-sensitive and procedurally complex, involving multiple stages of informal and formal components. RREs must then swiftly locate historical documentation, reconstruct claim decisions, and evaluate whether any safe harbors or protections apply – all while facing strict response deadlines.
ECS’ CMP Resolution Service is designed to serve as a compliance lifeline. Our team combines deep expertise with hands-on claim analysis. With the nation’s most talented and experienced of dedicated MSP attorneys, technical experts and claims leaders, we can guide your organization through this daunting process. Tapping into a rich background experienced in forensic data analysis, claim handling, and MSP policy expertise, our CMP Resolution Service provides the answers and assistance you need to mitigate and eliminate your organization’s CMP risks.
As CMS intensifies oversight and enforcement, RREs cannot afford a reactive or ad hoc approach. Our structured, expert-driven response materially reduces penalty risk and strengthens your overall Section 111 compliance posture. And, importantly, once mobilized to assess and assist, will stay with you to provide ongoing risk mitigation by identifying and recommending enhanced practices to eliminate future CMP risks.
And it’s just as important to be prepared for CMPs with ECS’ auditing service. We can identify reporting risks around data collection, the query process, ICD codes, TPA claims intake, conditional payments, MSAs and WCMSA reporting and more. Our experts analyze your data and claims processes, illuminate risks, and offer concrete ways to mitigate and eliminate compliance obstacles in a comprehensive report. It’s that ounce of prevention that’s worth more than a pound of cure.
For more information about our Civil Money Penalty Appeal Service or our full suite of comprehensive and customizable MSP Compliance and Section 111 Reporting solutions, please contact us at MSPCompliance@examworkscompliance.com or call our dedicated MIR Service Support line at (678)222-5454.
