CMS Updates Section 111 NGHP User Guide to Version 8.0

by F. Fairchok

The Centers for Medicare & Medicaid Services (CMS) recently published an update to the Non-Group Health Plan (NGHP) Section 111 Reporting User Guide. The refreshed User Guide, Version 8.0, contains updates relating to the new requirement for reporting Workers’ Compensation Medicare Set-Aside (WCMSA) information on claims that have reportable Total Payment Obligation to Claimant (TPOC) amounts.

Field Number Updates
Field numbers have been updated throughout the User Guide to align with the new data fields added for WCMSA reporting. CMS inserted new data fields into the User Guide when announcing the new requirement last year. However, they did not re-number the fields at that time to make it clear the changes were due to a future reporting requirement. The requirement to begin reporting WCMSA data started on April 4, 2025, for Total Payment Obligation to the Claimant (TPOC) dated on, or after, that date. This requirement is only for workers’ compensation (Plan Insurance Type = E) claims.

Event Table Updates
The Event Table – Table 6-12 in Chapter IV, Technical Information – has been updated to include new scenarios involving WCMSA corrections. This section reminds us that the process of sending a delete with a corresponding add continues when changes occur in the following fields:

• • CMS Date of Incident
  • Plan Insurance Type
  • Policy Number
  • ORM Indicator

Update transactions may be sent if the MSA Amount or MSA Period need correction.

Recovery Agent TIN
As of October 6, 2025, the Recovery Agent TIN will be required if a Recovery Agent Mailing Name is submitted in the TIN Reference File.

Commentary
The updates in Version 8.0 reflect CMS’s ongoing efforts to refine its reporting processes and ensure alignment with broader policy initiatives like WCMSA compliance. For RREs, these changes highlight the importance of staying informed about evolving requirements and adapting internal processes accordingly.

Here are some practical steps you can take to prepare for these updates:

1. 1. Review Internal Systems: Confirm that your claims management systems are updated to reflect the revised field numbers and reporting thresholds outlined in Version 8.0.
   2. Train Your Team: Provide training or resources for staff members who handle Medicare reporting, so they understand how these changes affect their workflows.
   3. Update Policies and Procedures: Revise your internal policies and procedures to incorporate the clarifications and new scenarios introduced in this update.

It is important to note that the new MSA data fields are mandatory to report on workers’ compensation claims with TPOCs dated on or after April 4, 2025. This means that claims reported without these fields will be rejected by CMS, and if the number of claims rejected in a quarterly file hit the 20% threshold, the entire file will be rejected. With Civil Money Penalties now being enforced, claim and file rejections may place the Responsible Reporting Entity in jeopardy of being penalized.

If you have questions about any changes made in version 8.0 of the NGHP User Guide, or are looking for further guidance on Medicare Secondary Payer (MSP) compliance, please don’t hesitate to email our experienced MSP Reporting services team at [email protected].