Legislative Updates

Resources Legislative Updates

New CMS Section 111 Reporting Alert

Posted by Genex on June 18, 2020

Keep current with new legislation and its potential effect on your organization. This regulatory update is for informational purposes only, and provides some key highlights on state initiatives that may impact the Medicare Set-Aside services Genex provides.

New CMS Section 111 Reporting Alert: Reporting No-Fault Insurance Limit on Non-Group Health Plan (NGHP) Claim Input Files

On the heels of CMS announcing July 2020 plans to upgrade the MSP Portal to allow authorized users to view and print correspondence, CMS has issued a new alert reminding Responsible Reporting Entities (RRE’s) of the importance of accurately reporting both Med Pay and Personal Injury Protection (PIP) coverage.

The alert, issued on June 8, 2020, reminds NGHP Responsible Reporting Entities (RREs) that both Med Pay and Personal Injury Protection (PIP) coverage should be included when reporting the No-Fault Insurance Limit (Field 61 of Claim Input File). NGHP RREs must combine both Med Pay and PIP coverage limits for a policy when they are separate coverages being paid out on claims for the same injured party and incident under a single policy.

CMS noted that some NGHP RREs were including only Med Pay when reporting the No-Fault Insurance Limit. CMS emphasized that both Med Pay and PIP coverage limits should be reported to accurately reflect the claim policy limit and Ongoing Responsibility for Medicals should not terminate until both the Med Pay and PIP coverage limits are exhausted. Likewise, to ensure reporting accuracy CMS stated that RRE’s should use two decimal places when reporting the No-Fault Insurance Limit (e.g. a policy limit of $5,000 should be reported as 500000).

As we continue to see CMS make upgrades to its systems and processes it is important that your organization has the appropriate Section 111 reporting protocols in place and an experienced reporting partner to ensure that information is accurately and timely reported to CMS.

For more information/questions about this Alert or to make a referral please contact Genex MSA  1.888.GO.GENEX or msadirect@genexservices.com. For additional information about NGHP reporting please access the most recent version of the NGHP User Guide in the downloads section here.


Need to reduce your total cost of risk?

To help lower your total cost of risk and return injured workers to work as quickly as possible, we offer a FREE consultation with a workers’ comp expert. Together, we will begin to build a workers' comp program to meet your company’s unique needs.