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CMS Releases Comments on Proposed Rule Regarding Section 111 Penalties


CMS just released the comments that were submitted by concerned entities in response to the CMS Proposed Rule regarding Section 111 penalties. The Proposed Rule discussed the criteria that would be used to determine when penalties would be imposed. The comments may be accessed by clicking here.


The comments submitted by Carr Allison were discussed in an earlier blog post and are available here. We are extremely concerned about the Proposed Rule given the significant penalties that would be imposed on Responsible Reporting Entities compared to the noncompliance. As drafted, we believe the Proposed Rule would be excessively burdensome and we are hopeful that it will be withdrawn. We will continue to follow this issue closely and keep you updated on future developments. If you have any questions about this or any other Medicare Compliance issue, please do not hesitate to contact us.

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