CMS Webinar August 13, 2020 Section 111 Mandatory Insurance Reporting for Non-Group Health Plans (NGHP). Questions and Answers Now Available

CMS, Mandatory Insurer Reporting, Medicare Set-Aside Blog on September 18, 2020
Posted by Noel D. Sturtz, Client Program Manager

Following up on our July 15, 2020 Blog, The Centers for Medicare & Medicaid Services (CMS) has released to the public the August 13, 2020 Section 111 NGHP Reporting webinar and Questions and Answers document. The presentation highlighted Section 111 reporting tips, best practices, and reminders, as well as Medicare Secondary Payer Recovery Portal (MSPRP) enhancements.

Key Takeaways:

  • If a Responsible Reporting Entity (RRE) is changing reporting agents, the new agent should continue to submit files under the RRE’s existing RRE ID(s). There is no need to go through the registration process to create a new RRE ID when changing reporting agents. However, it is the RRE’s responsibility to coordinate the transition of reporting from the former agent to the new agent.
  • CMS requires that ICD-10 codes be used for dates of incident/discharge on and after October 1, 2015. Any date of incident before that date can be reported using ICD-9 or ICD-10. It is critical to submit all diagnosis codes that pertain to the injury, but no codes for pre-existing or unrelated conditions.
  • There are very limited liability situations warranting a NOINJ (No Injury) Code.
  • Reporting thresholds – For Section 111 reporting, the current minimum reportable TPOC (Total Payment Obligation to Claimant) for Liability, No-Fault, and Workers’ Compensation claims is $750 – for Liability, TPOC dates as of 1/1/2017 and subsequent; for No-Fault and Workers’ Compensation, TPOC dates as of 10/1/2016 and subsequent. TPOC amounts exceeding those thresholds must be reported, while amounts less than the specific threshold may be reported and will be accepted. It was emphasized that non-trauma liability reporting for exposure, ingestion, and implantation must be reported.
  • Common Error Codes – CMS has been noticing the most common error codes being blank required fields (particularly State of Venue); blank first diagnosis code; invalid ICD codes; and blank ORM (Ongoing Responsibility for Medicals) Indicator field.
  • Toward ensuring exceptional service, an Escalation Process was elucidated toward addressing and prioritizing customers’ inquiries or issues.

CMS also announced additional enhancements (as of July 2020), including:

  • The ability to view and reprint correspondence from the Letter Activity tab when logged into the Portal.
  • The ability to see diagnosis code descriptions when hovering over the codes on the MSPRP Claims Listing page, and ability to view the ICD codes submitted via Section 111 reporting when logged into the Portal.

You may wish to view the webinar’s slide presentation and questions-and-answers by clicking on the links below:

For questions or concerns regarding Section 111 Reporting, please feel free to reach out to a member of our team at