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CMS holds Section 111 NGHP update webinar

This article was updated on September 17, 2020.

On August 13th, the Centers for Medicare and Medicaid Services (CMS) held a webinar session on Section 111 non-group health plan (NGHP) reporting. CMS did not provide an agenda before the call or otherwise give any indication as to the topics and areas it planned to discuss.

As part of this fifty-five-minute session, CMS conducted opening remarks followed by a presentation regarding what it described as NGHP Section 111 reporting best practices and MSPRP enhancements. The meeting concluded with a participant question and answer session. As the agency has done on past calls, it referred the audience to the NGHP Section 111 User Guide as the governing document regarding any perceived discrepancies between what the CMS panel discussed on the call and the applicable directives set-forth in the User Guide. Of note, at the outset of the webinar, CMS advised it would not address its pending Section 111 civil money penalties (CMPs) proposals. 

The following provides a general overview of the main items addressed by CMS on this webinar:

General Section 111 reminders and items

CMS discussed as it described them, various “tips” for RREs which included, in part, reminders regarding the following Section 111 activities: the process for changing reporting agents; correct recovery agent reporting; diagnosis code reporting (ICD 10 only post 10/1/15); appropriate use of the no injury (noinj) code; file submission timeframes; TPOC reporting thresholds; and  file level threshold errors. Other topics included reminders regarding CMS’s recent Alert addressing combining PIP and med pay data if both coverages exist when reporting, TIN reference response file, and trending and common error codes. Overall, CMS did not announce any new policy guidance regarding these items. Its presentation was really focused on just reiterating existing policy directives, the majority of which have been in place for quite some time and contained in the NGHP User Guide. 

MSPRP Enhancements

CMS also discussed recently made enhancements to the Medicare Secondary Payer Recovery Portal (MSPRP).  The main items the agency addressed here involved  the addition of what it described as the “previous button” to facilitate navigation in screen use, the ability to view and print CMS recovery correspondence from the letter activity tab, and the ability for users to provide additional information regarding the claim for recovery activities. Click here to see our recent article on the MSPRP updates.

Q&A Session

CMS then opened the lines for a thirty-minute question and answer session. View CMS's question and answer document here. As part of the Q/A session, CMS received questions on different Section 111 topics from which, in part, it noted that an entity reporting both liability and workers’ compensation claims could use the same RRE; advised updated ICD 9 and ICD 10 lists will be available on October 5th, and confirmed entities may update ICD 9 codes to ICD 10 if appropriate to the nature of the injury. Also, CMS advised all “nines” should be in the field value when reporting unlimited no-fault policies, not zeros.

CMS’s PowerPoint Presentation and Future Webinars

A copy of the Power Point CMS used for this webinar can be obtained here. As for other matters, CMS also mentioned that it plans on holding future Section 111 webinars, although no date or time frame was indicated. 

Recent ISO CP Section 111 articles

In addition to CMS’s webinar summarized above, there have been several other Section 111 updates over the past several months. 

Below are links to our recent Section 111 articles addressing current reporting issues:

OIRA releases updated information on Section 111 CMPs

CMS’s Section 111 civil money penalties comment period closes

CMS’s Section 111 penalty proposals are here

CMS releases new NGHP Section 111 User Guide (Version 5.9)

CMS releases Section 111 alert regarding the reporting of no-fault insurance and med-pay policy limits on claim input files


ISO Claims Partners will continue to monitor all updates regarding Section 111, including CMS’s outstanding CMPs proposals, and will provide updates as warranted. In the interim, please do not hesitate to contact the authors if you have any questions. 

Kate Riordan, J.D.

Kate Riordan, J.D., is director of Medicare Secondary Payer initiatives for Casualty Solutions at Verisk. You can contact Kate at

Jeremy Farquhar

Jeremy Farquhar is a senior product consultant, Casualty Solutions at Verisk. You can contact Jeremy at

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