CMS has released Version 8.6 of the MMSEA Section 111 NGHP User Guide, introducing several updates and clarifications affecting Responsible Reporting Entities (RREs) involved in Workers’ Compensation, Liability, and No-Fault reporting.
While the update does not introduce major reporting rule changes, it contains important guidance related to non-submission notifications, wrongful death reporting, Qualified Settlement Funds (QSFs), and future system enhancements scheduled for implementation in April 2027.
What’s New in Version 8.6?
| Update | Details & Implications |
|---|---|
| MSP Center Email Address Updated Chapters 1 & 2 | CMS updated the User Guide to reflect that communications previously sent from COBVA@mail.cms.hhs.gov will now be sent from MSPCenter@cms.hhs.gov. Organizations should ensure email filters and internal processes recognize the new address to avoid missing important Medicare Secondary Payer communications. |
| New Non-Submission Notification Emails Chapter 6 | One of the most notable updates in Version 8.6 is the addition of a non-submission notification process. CMS indicates an email may be sent when an NGHP RRE has not submitted a Claim Input File within the previous six months. This update is particularly important because not all RREs have claims to report during every reporting period. Organizations should understand that receipt of a non-submission notification does not automatically indicate a reporting violation, but it should prompt a review of reporting obligations and filing activity. |
| Wrongful Death Reporting Clarified | CMS updated the User Guide to provide additional clarification regarding when a record must be submitted for a wrongful death claim under Section 111 reporting requirements. This update may be especially relevant to General Liability reporting programs, where wrongful death settlements can present unique reporting considerations. |
| Qualified Settlement Fund (QSF) Exception Clarification | The revised User Guide also includes updated language regarding the reporting exception for Qualified Settlement Funds (QSFs). Organizations involved in complex liability settlements should review this clarification carefully to ensure reporting practices remain aligned with CMS guidance. |
| Important Changes Coming in April 2027 | CMS announced several future system updates that reporting entities should begin preparing for now. TPOC and WCMSA Value Corrections Beginning in April 2027, CMS systems will be updated to accommodate the removal of TPOC and WCMSA data when existing non-zero values are being updated to zero for Section 111 ORM Workers’ Compensation and No-Fault claims. This enhancement is intended to provide greater flexibility when correcting previously reported information. NOINJ Diagnosis Code Retirement Effective April 2027, the diagnosis code NOINJ will no longer be accepted by CMS. According to the User Guide, claims involving no injury generally do not require reporting, eliminating the need for the code going forward. |
Why This Matters
Several of these updates reinforce CMS’s continued efforts to improve reporting accuracy, communication, and system functionality.
Key considerations for RREs include:
- Monitoring communications from the new MSP Center email address.
- Understanding the implications of non-submission notification emails.
- Reviewing wrongful death reporting obligations and requirements.
- Evaluating QSF reporting practices and applicable exceptions.
- Preparing internal systems and processes for the April 2027 reporting changes.
While Version 8.6 does not contain sweeping reporting changes, the clarifications included in the update may affect day-to-day Section 111 reporting operations and future compliance planning.
Takeaway
The release of Version 8.6 serves as another reminder that Section 111 reporting requirements continue to evolve. Organizations should review these updates carefully, assess any impact on existing reporting workflows, and ensure compliance processes remain aligned with current CMS guidance.
For organizations seeking additional support, Allan Koba Compliance Solutions can help evaluate Section 111 reporting programs, strengthen compliance processes, and navigate evolving Medicare Secondary Payer obligations.
