CMS Clarifies Prior TPOC Alert in an Update to the NGHP User Guide
Brendon De Souza
On December 20, 2021, the Centers for Medicare & Medicaid Services (CMS) updated the NGHP User Guide (Chapter III: Policy Guidance) to incorporate a prior Total Payment Obligation to Claimant (TPOC) alert into CMS’ formal policy guidance. CMS has established the following bright-line rule for timely reporting TPOCs:
126.96.36.199 Timeliness of Reporting
NGHP TPOC settlements, judgments, awards, or other payments are reportable once the
following criteria are met:
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