CMS Section 111 NGHP Civil Money Penalties: Quarterly Audits Are Live and the 30-Day Mitigation Clock Starts at Informal Notice
CMS operationalized NGHP Section 111 civil money penalty enforcement through randomized quarterly audits beginning Q1 2026. RREs face penalties up to $365,000 per record with a fixed 30-day mitigation window — no extensions — after an Informal Notice.