CMS Issues Alert Maintaining $750 Threshold for 2022


On December 15, 2021, CMS issued an alert confirming that they will maintain the current $750 TPOC reporting threshold for 2022. Physical trauma-based liability TPOC amounts of $750 or less do not have to be reported to CMS, and workers’ compensation and no-fault TPOC amounts of $750 or less do not have to be reported when the RRE does not otherwise have ongoing responsibility for medicals. CMS will also not seek recovery for such cases.


Please note that the $750 threshold does not apply to liability cases involving alleged ingestion, implantation, or exposure. TPOCs of any amount are reportable for such cases. It is important to remember that CMS looks at the cumulative TPOC amount in determining whether the $750 threshold is met. This means that a claim is reportable if an RRE has multiple TPOCs that together exceed the $750 threshold.


If you have any questions about Section 111 reporting, please let us know. We will be happy to assist.

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