Author: Logan Pry, VP, Medicare Compliance

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 added explicit language emphasizing that the most current Medicare ID will be returned in both Query Response and Claim Response files when a beneficiary match is found.
  • $750 Threshold Retained (Chapter III)
    CMS is continuing the $750 threshold for no-fault claims without ongoing responsibility for medicals. This marks the tenth consecutive year the threshold remains unchanged.
  • File Submission and Response Updates (Chapter IV)
    Additional verbiage has been added in the technical chapter – Chapters IV (subsections 3, 7, and 8.1) to help clarify how updated beneficiary information is provided via response files, aiming to reduce confusion and ensure consistent reporting.

 

Why This Matters

  • Precision in Medicare ID: Ensuring most current Medicare IDs helps prevent record mismatches and improves the accuracy of your Section 111 reporting. Determining whether a claim triggers a Section 11 reporting obligation begins with a determination of Medicare eligibility.
  • Threshold consistency: Maintaining the $750 benchmark helps RREs avoid surprises and supports stable internal processes.

Each chapter of the updated User Guide can be downloaded here – https://www.cms.gov/medicare/coordination-benefits-recovery/mandatory-insurer-reporting/user-guide.

 

Coming Soon: Civil Money Penalties Webinar

CMS has announced a webinar on CMPs related to NGHP reporting on January 15, 2026 at 1 PM EST. It’s a valuable opportunity to hear directly from CMS about enforcement expectations. While the webinar announcement (here – https://www.cms.gov/files/document/december-8-2025-nghp-cmp-webinar-announcement.pdf) indicates the subject matter will include reminders about the Final Rule governing Civil Monetary Penalties and the auditing process, there will also be a Q&A session which always proves to beneficial for attendees.

 

Takeaway:

The updated User Guide and the webinar announcement serve as a reminder that the period in which claims may be audited for Civil Monetary Penalties has begun and that now is the best time to review your Section 111 Reporting program and ensure total compliance. Make your 2026 resolution to stay CMP free.

Contact us today for more information on how Allan Koba Compliance Solutions can help you avoid penalty as well as our new indemnification suite for Section 111 Mandatory Insurer Reporting services.