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Section 111 Reporting to CMS

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Section 111 of MMSEA requires group health plans to collect and report information on covered participants/dependents who are or may become eligible for Medicare coverage.

A TPA has been performing this task as required but recently came across Social Security Numbers provided by a plan participant that appear to be false. (The Area Numbers are all in the 900's.)

Given the penalties for non-compliance the TPA is trying to determine if it has any obligation to report the problem or if should merely pass the reported information along to CMS.

Thanks in advance.

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