CMS Section 111 TPOC Reporting Commences 1.1.2012

  • August 29, 2011
  • Written By Perr&Knight
Reading Time: 2 minutes

The Total Payment Obligation to the Medicare beneficiary (TPOC) refers to the dollar amount of a settlement, judgment, award, or other payment in addition to/apart from ongoing medical responsibility.  For liability insurers and self insurers, data must be captured for TPOC’s occurring after 10.1.2011 – and production level reporting will commence within the first quarter of 2012.
As such, we want to remind our clients to focus on preparing claims workflows and data capture in anticipation of these dates quickly approaching.


As you prepare, it is important to remember that:

  • Compliance is not simply a straightforward “data reporting” process as many vendors in the market place insist.
  • In fact, it is being reported that many vendors that don’t have the proper expertise are having significant challenges in adapting to medical claims based reporting.
  • Without a comprehensive, turn-key solution, reports to Medicare may be timely but fines could still be imposed at some point within the program due to erroneous reporting of data elements.
  • Ongoing education and management is required to comply with a Federal mandate that will continue to have rules changes – probably for the next few years.
  • Medical Set Asides (MSA’s) – which have traditionally been done only for workers compensation – will soon also be required for all liability lines and the terms of these agreements will have to be incorporated into the Section 111 quarterly reports filed.
  • This truly is a complex program initiative for all entities required to participate.


Perr&Knight’s proven consulting services provide excellent functional support to our growing Medicare Section 111 reporting community.  This focus – along with our flexible, user friendly data portal and advanced technical capabilities – provides a value add that must be strongly considered. Our services ensure that our clients are kept aware of the latest changes in the Medicare guidelines and our data portal is maintained so that the CMS rules are continually updated and proper error analysis is conducted – which are both included in your “turn-key” solution fees for administering the reporting function.

We also recognize that many clients would like a “one stop shop” that handles both the Medicare Section 111 Reporting as well as the Medicare Set Aside (MSA) work. To this end, we have aligned ourselves with a well experienced partner should your company have a need for this service as well.


We understand the need for insurers to control costs in today’s economy; therefore, our set up and quarterly reporting fees are very fair for a comprehensive solution that focuses on consulting; ensures successful registration, testing and reporting; and empowers our clients with a data portal that will be updated continually to ensure Medicare reporting compliance for our client community.


Please contact us for more information.