Section 111 Mandatory Insurer Reporting Update: Top 10 Errors and Empty NGHP Unsolicited Response Files

Last Updated: 11 Aug 2023

Author: Logan Pry

CMS has recently published an updated list of the Top 10 Section 111 NGHP Reporting error codes. This list is based on data received from January 1, 2023 through June 30, 2023. While the full breakdown can be found here - A snapshot of the top 10 errors is as follows:



While three of the top ten errors are “soft errors” and will not trigger an error threshold kickback as a result, of interest are a few of the top vote getters; namely, invalid Termination Date and Invalid Diagnosis Code 1. While RREs should ensure that their entire claim input file is accurate and error-free, these fields may be of particular interest as they can have a direct impact on your conditional payment recovery activity. Not properly terminating ORM when applicable, as well as improper coding can leave an RRE with an uphill battle when disputing conditional payment demands.

CMS last published this list in January for data collected for the previous 6-month period of July 1, 2022, through December 31, 2022.  The new data set shows an increase of total number of errors received among the top 10 (an increase of about 39,500 errors to 42,600 through 6 months this year) as well as a shift in the errors making the top 10 list.

CMS also recently pushed an alert indicating that they have received questions regarding empty unsolicited response files. Within this alert, the agency has confirmed that if an RRE has opted in to the Unsolicited Repose file receipt, they will always receive a file in return and in the event that there are no records updated by an outside source to be included one the unsolicited response file, then it will be blank. This alert also indicates that the NGHP User Guide will be updated to clarify and confirm that RREs will receive blank response files if there is no data to update.

For questions about these updates, as well as general inquiries about Section 111 reporting and Medicare recovery correspondence, please contact us at

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