Our Insights

Author: Jeremy Papp, Esq. The Centers for Medicare & Medicaid Services (CMS) has released the latest version of the WCMSA Reference Guide. Effective July 17, 2025, CMS will no longer accept or review WCMSA proposals with a zero-dollar ($0) allocation. Entities must now consider specific parameters to determine if a $0 WCMSA allocation is appropriate […]

Author: Logan Pry On October 7th, CMS released Version 7.7 of the MMSEA NGHP User Guide with a few key updates. This iteration adds additional information regarding the steps needed and the emails that are issued during RRE registration, specifically Ch. 1 Table 7-1, Ch. 2 Table 6-4, and Ch. 4 Table 12-1. In general, these […]

Author: Logan Pry 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 […]

Author: Logan Pry CMS has released its first version of the Non-Group Health Plan Section 111 Reporting User Guide of 2024. Not long after a recent informational webinar regarding Civil Monetary Penalties held on January 18, CMS released version 7.4 of the User Guide, in which the primary update is the addition of Ch. III, sect. […]

Author: Ciara Koba CMS hosted a live webinar on January 18th at 1pm EST.  This webinar provided valuable information for responsible reporting entities (RREs) as the industry prepares for CMS to begin quarterly compliance audits and the imposition of civil monetary penalties.  Please find the highlights of the webinar below and if you have further questions about […]

Author: Logan Pry CMS has announced that it will be hosting a webinar on November 13th, 2023, regarding a coming expansion to Section 111 reporting. Specifically, the announcement indicates that expansion will involve expanding TPOC reporting to include WCMSA information. The webinar will include a presentation by CMS providing general information and timelines, and should also […]