New Section 111 reporting thresholds

The Centers for Medicare and Medicaid Services posted the following Alert on September 26, 2016 with updated thresholds for Section 111 reporting.

As background, on December 29, 2007, President George Bush signed into law the Medicare Medical, and SCHIP Extension Act of 2007. The purpose of the Section 111 Medicare Secondary Payer reporting process is to enable the Centers for Medicare & Medicaid Services (“CMS”) to pay for Medicare covered items and services furnished to Medicare beneficiaries by determining primary versus secondary payer responsibility. Specifically, Section 111 adds mandatory reporting requirements for group health plan (“GHP”) arrangements and liability insurance (including self-insurance), no-fault insurance, and workers’ compensation. The reporting requirements do not eliminate any other existing statutory provision (e.g. claimant’s counsel must still identify pending liability claims to CMS and CMS’s interest must be protected in all settlement agreements, judgments, awards, or other payment.).

On September 26, 22016 CMS published an alert with new thresholds.  It stated that, as of the date of the alert and for the remainder of 2016, CMS will maintain the $1,000 threshold for physical trauma-based liability insurance (including self-insurance) settlements. CMS will also implement a $750 threshold for no-fault insurance and workers’ compensation settlements, where the no-fault insurer or workers’ compensation entity does not otherwise have ongoing responsibly for medicals.

If you have any questions about your responsibility regarding Section 111 reporting, please feel free to contact me at

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