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CMS releases new NGHP Section 111 User Guide (Version 5.8)

By Mark Popolizio, Jeremy Farquhar  |  February 12, 2020

The Centers for Medicare and Medicaid Services (CMS) has released an updated Section 111 User Guide (Version 5.8, January 31, 2020) regarding non-group health plans (liability, no-fault and workers’ compensation). This updated guide replaces Version 5.7 (October 7, 2019). Overall, the updates are on the minor side and do not announce any new requirements or substantive changes to reporting. 

Per CMS, the reported changes were made to Chapter III (Policy Guidance) and Chapter IV (Technical Information) consisting of the following:

Both Chapters were updated to incorporate CMS’s December 2019 Alert through which CMS announced that it was retaining its $750 low dollar reporting threshold. As part of this incorporation, CMS states the following as part of the User Guide updates to both Chapters III and IV:

As of January 1, 2020, the threshold for physical trauma-based liability insurance settlements will remain at $750. CMS will maintain the $750 threshold for no-fault insurance and workers’ compensation settlements, where the no-fault insurer or workers’ compensation entity does not otherwise have ongoing responsibility for medicals. (Section 6.4.2, 6.4.3, and 6.4.4).

For more information regarding the parameters of CMS’s low dollar reporting threshold, please see the User Guides sections in both Chapters III and IV as cited above by CMS as part of this update.

In addition, regarding Chapter III, CMS states: “[p]olicy language regarding Medicare Secondary Payer (MSP) recovery efforts has been updated (Chapter 4).”  From the authors review, these updates relate to grammatical and formatting changes and do not impact any substantive reporting requirements.

If you have any questions on these updates, please contact Mike Gibbon at, or Jeremy Farquhar at

Mark Popolizio, J.D., is vice president of MSP compliance and policy at ISO Claims Partners, a Verisk business. You can contact Mark at

Jeremy Farquhar is a senior product consultant at ISO Claims Partners, a Verisk business. You can contact Jeremy at