Our Insights

CMS opened 2026 with additional clarity on the Civil Money Penalty (CMP) enforcement timeline during its January 15th webinar, offering important operational details for Responsible Reporting Entities (RREs) preparing for the first audits under the Section 111 Final Rule. While much of the rule’s framework has already been published, CMS used this session to reinforce […]

To start 2026, CMS released Version 8.3 of the MMSEA Section 111 NGHP User Guide just five days into the year. Although not a voluminous overhaul, this update delivers several key clarifications and reminders that Responsible Reporting Entities should review carefully.   What’s New in Version 8.3? Medicare Query Result Clarification (Chapters I, II & IV) CMS […]

As of April 2025, the new Section 111 reporting requirements mandate the inclusion of MSA data for all workers’ compensation settlements, regardless of whether the voluntary MSA review process with CMS was followed. CMS has indicated that the reported data would be posted with a “W” to each applicable beneficiary’s Common Working File (CWF), thereby […]

Attention all workers’ compensation carriers! Are you ready to revolutionize how you handle Medicare set-asides in nuisance value cases? Say goodbye to the old, cumbersome processes and hello to our innovative MSA111 product, designed specifically to help you plug the gaps and streamline your compliance efforts. 🌟 Why MSA111?  If you’re settling cases with a Medicare beneficiary and […]

With all of the recent changes, updates, and alerts coming from CMS, it is important to remember that various aspects of MSP compliance directly impact one another. Namely, Section 111 reporting and conditional payment appeals. This past week, AKCS was tasked with resolving a lien in excess of $350,000 and a detailed analysis of the […]

On August 8th, CMS issued an alert confirming that COBSW system updates are coming soon. The Section 111 Coordination of Benefits Secure Website (COBSW) provides general information on Section 111 reporting, links and instructions, reference materials including various user guides, as well as a secure portal which provides the ability to manage your RREs, run […]