Compliance Update: MMSEA Section 111 Reporting

Last Updated: 06 Feb 2023

Author: Logan Pry, Vice President of Medicare Compliance

CMS opened 2023 with a series of updates to the NGHP Section 111 User Guide. First, on January 9, a new version of the User Guide – version 7.0 – was published. While several of the updates contained in this new iteration were informative only, including confirmation that the $750 settlement threshold will stay the same, and updates regarding soft edits; the most interesting update was perhaps the addition of the NGHP Unsolicited Response File. Beginning July 2023, RREs will have the ability to opt in (via the Section 111 portal – COBSW) to receive a monthly response file providing information regarding updates to ORM records (not made by the RRE) submitted within the last 12 months and permit RREs with the option to either update their own data or submit a request for a correction.


Table 7.3 of Ch. IV outlines the changes that may have been made to a record, as well as the response codes that indicate the type of unsolicited modification that has been made to the record. Table 7.3 can be found here -


Shortly after the publication of Version 7.0, two quick edits followed – one addition, and one redaction.
These changes issued on 2/1 and 2/3 respectively simply clarified the fields that would be provided on the Unsolicited Response file.


Over the last two years, RREs have seen a spike in correspondence received from CMS indicating that information regarding ORM on file conflicts with other information received. At times, identifying the source of the conflicting information, and then correcting the file as needed has been very work intensive. Opting in to the Unsolicited Response file should give RREs some much needed assistance in identifying the source of any changes made to an ORM record, and then updating and/or correcting the Section 111 reporting as needed.


Each chapter of the updated User Guide, Version 7.0 is available for download here -


Don’t hesitate to contact Allan Koba Compliance Solutions with any questions about these updates as well as general inquiries regarding your Section 111 Reporting program at

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