Section 111 Reporting Update

Last Updated: 16 Nov 2021

Author: Logan Pry, Esq.

Over recent weeks, CMS has posted a duo of alerts to the Non-Group Health Plan Mandatory Insurer Reporting landing page. While these alerts do not place any new obligations or requirements on Responsible Reporting Entities, they do provide some helpful reminders, coupled with a bit of guidance.

The first alert, released October 26, 2021, provides RREs with a reminder to update their Section 111 reporting when applicable. Specifically, here, RREs are being reminded to update their No-Fault policy limit in the event that it changes. The alert provides the following example – “a policy allows for a minimum amount of MedPay coverage and will only allow a higher amount under certain circumstances, and those circumstances are not yet met at the time of reporting, the RRE should report the lower amount. Should the criteria that triggers the higher policy limit be met after that report, the RRE should update the record as soon as possible.” The alert goes on to remind us that reporting incorrect information, or failing to update the claim record as needed can put the RRE at risk of non-compliance with the Section 111 reporting requirements.

The full text of the alert can be found here -

The second alert, released November 3, 2021, reminds RREs that in the event that funding of a settlement, or TPOC, is delayed until after the settlement date, the RRE should report the actual, or estimated, date of the funding in field 82 of the claim input file – “Funding Delated Beyond TPOC Date”. Failing to use this field when funding is delayed can cause CMS to initiate recovery demands before funds for the settlement have been received by the beneficiary. Obviously, this can negatively impact the beneficiary, can cause confusion and additional work for all parties involved. In addition, this field is available to RREs to ensure that they may still report TPOC events in a timely manner pursuant to current reporting guidelines on timely reporting, even when funding may be delayed for any reason.

The full text of this alert can be found here -

These alerts serve as a helpful reminder as we move toward the end of the year to ensure that your Section 111 Reporting program is in full compliance with current guidance in light of information received about the proposed rules for civil monetary penalties over the last year, as well as the implication of the PAID Act updates to the query process.

Allan Koba Compliance Solutions continues to monitor updates to the Section 111 Mandatory Insurer Reporting requirements as well as all other Medicare Secondary Payer matters. For questions and more information, please contact us at

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