CMS Clarifies Use of Empty Unsolicited Response Files

by F. Fairchok

The Centers for Medicare & Medicaid Services (CMS) provided a notice on July 12, 2023, to clarify that NGHP Responsible Reporting Entities that have elected to receive Unsolicited Response Files will receive a file each month, even if no records have been updated by an outside source. Unsolicited Response Files are generated on the second Sunday of each month and contain any updates made in the previous 30 days. If no updates are found for that period, the file will only contain the header and trailer records.

The text included in the notice is as follows:

Questions have been received from NGHP Responsible Reporting Entities (RREs) regarding receipt of empty (header and trailer record only) Unsolicited Response Files. Please be aware that a file will be transmitted regardless of record count.  This means that an RRE that has opted in to receive the Unsolicited Response File will always receive a file that includes any updates made in the last 30 days.  If there are no records updated by an outside source that are linked to that RRE ID in that timeframe, the Unsolicited Response File will be empty.  Please note that the NGHP User Guide will also be updated to clarify the receipt of empty files.

IMPAXX will be publishing a comprehensive guide to the newly implemented Unsolicited Response File functionality shortly, but in the meantime, please don’t hesitate to email us with any questions at [email protected]. If you are looking for further guidance on Section 111 reporting compliance, our experienced Medicare Secondary Payer Reporting services team can collaborate with you to customize the compliance experience to meet your unique needs and requirements. Contact us today to learn more.