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CMS releases new WCMSA Reference Guide and NGHP Section 111 User Guide

The Centers for Medicare and Medicaid Services (CMS) has updated its Workers' Compensation Medicare Set-Aside (WCMSA) Reference Guide and Non-Group Health Plan (NGHP) Section 111 User Guide.

These new updates include the following:

New WCMSA Reference Guide (Version 2.8, October 1, 2018)

The main change relates to CMS’ ongoing Social Security Number Removal Initiative (SSNRI) and Medicare Beneficiary Identifier (MBI) process through which CMS is required to reissue new Medicare cards removing the current SSN-based number with a new unique MBI. CMS is currently reissuing the cards in geographic waves and is required to have all new Medicare cards issued by April 2019.

In relation to this, the new WCMSA Reference Guide was updated to align with the MBI changes. In a going forward basis, CMS will be using a MBI, instead of a Health Insurance Claim Number (HICN), when identifying beneficiaries in WCMSAs. However, parties can still submit the HICN to CMS. Outside of this, CMS updated the charts for determining jurisdiction when calculating the pricing in the WCMSA. The methodology to determine the applicable jurisdiction did not change, but CMS provided some additional clarity and context through examples. CMS also introduced a new chart that matched the resulting jurisdiction with the applicable pricing schedule. Finally, CMS updated the link to the current Centers for Disease Control (CDC) life expectancy table.

New NGHP User Guide (Version 5.4, October 1, 2018)

There were changes made to the Sec. 111 NGHP User Guide in this most recent version. These updates include, per their respective chapter, the following:  

Chapter 1

  • To meet Section 111 requirements, a Paperwork Reduction Act (PRA) disclosure statement has been added to this guide.
  • The contact protocol for the Section 111 data exchange escalation process has been updated (Section 8.2).

Chapter 2

  • The contact protocol for the Section 111 data exchange escalation process has been updated (Section 7.2).

Chapter 3

  • No updates

Chapter 4

  • To ensure updates are applied to recovery cases appropriately, RREs are asked to submit the policy number uniformly with a consistent format. When sending updates, enter the policy number exactly as it was entered on the original submission, whether blank, zeros, or a full policy number (Section 6.6.5).
  • The contact protocol for the Section 111 data exchange escalation process has been updated (Section 13.2).

Chapter 5

  • To ensure updates are applied to recovery cases appropriately, RREs are asked to submit the policy number uniformly with a consistent format. When sending updates, enter the policy number exactly as it was entered on the original submission, whether blank, zeros, or a full policy number (Appendix A, Claim Input File, Field 54).
  • Placement of decimals for the ICD-10 Excluded “Y” diagnosis codes has been corrected (Appendix I).
  • The excluded and no-fault excluded ICD-10 diagnosis codes have been updated for 2019 (Appendix I and Appendix J).

If you have any questions regarding these updates, please contact the author directly.


Sid Wong, J.D.

Sid Wong is the Vice President of Policy at Verisk Casualty. In this capacity Sid monitors and evaluates the changing state of Medicare Secondary Payer compliance to develop impactful solutions to emerging MSP issues and works to ensure that Verisk’s Casualty’s policies, products, and services continue to align with the MSP landscape. He also oversees Verisk Casualty’s policy team, which provides policy and compliance support for all of Verisk Casualty’s clients. During his tenure he has served as Legal Director, Assistant Director of Services, Client Solutions Manager, and MSP Compliance Manager. Sid is a subject matter expert on MSAs, Conditional Payment Recovery, and Section 111 reporting. He collaborates with clients to develop best practices and respond to any compliance or policy questions, whether it’s a case level issue or evaluating a process impacting the larger organization. He regularly presents at industry conferences and provides training for clients.

Prior to joining Verisk, Sid worked for a small general practice firm in New Hampshire where he received his JD from University of New Hampshire Franklin Pierce School of Law. Sid is a member of the MA, NH, and NY bar, the IAIABC, NAMSAP, MARC, and is MSCC certified.


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