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RIMS Submits Recommendations for Imposing SMART Act Tax Penalties for Noncompliance 2/19/2014



RIMS Letter to Centers for Medicare and Medicaid Services Reinforces its Commitment to Streamlining the Insurance Process

NEW YORK (February 19, 2014) – RIMS, the risk management society ™, delivered an official letter to the Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) highlighting recommendations to fairly impose tax penalties on organizations that fail to comply with the SMART Act.

The letter, submitted by RIMS President Carolyn Snow, offers the following recommendations, among others, that should be considered by the governing agency:

  • “Noncompliance” should be clearly defined in a way that is consistent with Medicare Secondary Payer statutes and regulations;
  • A clearly defined metric for determining the extent of the monetary penalty should be developed;
  •  A sliding scale of monetary penalties should be implemented;
  • CMS should establish a safe harbor for entities that make good faith effort to obtain pertinent information from beneficiaries or claimants; and
  • CMS should give a reasonable timeframe allowing violators to assert a defense.

“As many RIMS members regularly handle cases involving conditional Medicare payments, the authorization of the SMART Act was a great victory for risk practitioners that will undeniably streamline the settlement process,” said RIMS President Carolyn Snow. “RIMS intends to be a vocal player during the SMART Act’s implementation, ensuring that it serves the best interests of all parties involved.”

To read the full letter, click here.

For more information about RIMS External Affairs initiatives, visit

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About RIMS

As the preeminent organization dedicated to advancing the practice of risk management, RIMS, the Risk Management Society™, is a global not-for-profit organization representing more than 3,500 industrial, service, nonprofit, charitable and government entities throughout the world. Founded in 1950, RIMS brings networking, professional development and education opportunities to its membership of more than 11,000 risk management professionals located in more than 60 countries. For more information on RIMS, visit


For more information, contact:

Josh Salter, RIMS communications manager, (212) 655-6059 or


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