Section 111 Civil Monetary Penalties: The Proposed Rule and What You Can Do Now To Get Your Compliance Program on Track

Medicare requires carriers and self-insureds to report certain information to Medicare. This is usually referred to as Section 111 reporting and Medicare uses the information to assist in its lien recovery process. Failure to properly report a claim under the section 111 requirements can result in penalties of over $1,000.00 per day per claim.  This presentation will cover the general requirements of section 111 reporting, Medicare’s proposed administrative rules to enforce these penalties, and its ramifications on a carrier/self-insured (or potentially their TPA.

Patrick Czuprynski
Director of Lien Resolution, NuQuest

Patrick Czuprynski is NuQuest’s Director of Lien Resolution. In addition to leading the lien resolution team, he represents debtors in conditional payment administrative appeals and negotiations through the Medicare Appeal Council and provides consulting services for settlements and Section 111 inquiries. Mr. Czuprynski presents webinars on Medicare secondary payer compliance on behalf of NuQuest. He has also been published in the Illinois State Bar Association Workers’ Compensation Newsletter, the ISIA Newsletter, The National Alliance of Medicare Set-Aside Professionals publication, Workers’ Compensation Law, and the Maryland State Bar Association publication. An attorney, licensed in Illinois, Mr. Czuprynski is a member of the National Alliance of Medicare Set-Aside Professionals, serving on the Legal Round Table, Policy and Legislation and Liability MSP Advisory committees. Mr. Czuprynski holds a J.D. from Valparaiso University Law School, and a B.B.A from University of Wisconsin Green Bay.

Bridget Smith
VP of Compliance and Customer Relations, NuQuest

Prior to joining NuQuest, Ms. Smith received her undergraduate Political Science Degree from Gannon University and received her Master of Arts and Juris Doctorate degrees from Duquesne University. She thereafter served as a judicial clerk for the Hon. Dante Pellegrini, President Judge of the Commonwealth Court of Pennsylvania. Ms. Smith went on to practice as a shareholder at a top Pittsburgh law firm serving as Vice-Chair of the Medicare Compliance Group. She concentrated her practice in the area of Medicare compliance as well as workers’ compensation litigation, medical malpractice, and general insurance defense. Ms. Smith also served as a Medicare compliance attorney and shareholder for a national defense firm and worked as in-house counsel for a leading Pittsburgh health facility. Ms. Smith was selected for inclusion in the Pennsylvania Rising Stars list of outstanding young attorneys in 2008 and has been listed in Best Lawyers since 2011 in the area of workers’ compensation. Ms. Smith is involved in various charitable organizations and serves as a volunteer faculty advisor for a local high school trial advocacy team. Ms. Smith is licensed to practice law in Pennsylvania and West Virginia. In her role as VP of Compliance and Customer Relations, Ms. Smith utilizes her extensive compliance, litigation, and workers’ compensation experience to provide customers guidance on Medicare Secondary Payer (MSP) issues . She has lectured throughout the country on MSP compliance and has written numerous articles on various subjects.