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Section 111 Penalty Proposal

There has been a lot of talk regarding Section 111 Civil Money Penalties and now the proposal is finally here. We have summarized the key points below and attached a brief document with links to easily analyze and determine what they mean to you as a Responsible Reporting Entity (RRE).

Civil Money Penalties (CMP) will be imposed in the following instances:

– Failure to report or delayed reporting

– Reporting inconsistent data

– Error tolerance threshold is exceeded

Civil Money Penalties (CMP) will not be imposed if:

– The RRE complies with reporting thresholds or exceptions

– Does not exceed error tolerance thresholds

– Makes a good faith effort to submit on time

Game plan would be:

– Making sure clean data is provided in a timely fashion

This document is PROPRIETARY/CONFIDENTIAL and ONLY available to PACE Claim Services LLC, clients, employees and contractors for business purposes. Third party distribution without permission is prohibited

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