CMS Issues Updated Section 111 User Guide


CMS recently released an updated Section 111 User Guide (Version 6.2) including the changes discussed below.


Extension of $750.00 TPOC Threshold

The User Guide reflects that the $750.00 TPOC reporting threshold continues to apply. For physical trauma-based liability cases, RREs are not required to report TPOC if the cumulative TPOC amount is $750.00 or less. For workers’ compensation and no-fault cases, RREs are not required to report TPOC if the cumulative TPOC amount is $750.00 or less and the RRE does not otherwise have ongoing responsibility for medicals.


Future ORM Termination Dates

RREs can now enter a future ORM Termination Date up to 75 years in the future. RREs should only report a future ORM Termination Date if the termination of ORM is certain to occur.


Policy Number is Now a Key Field

CMS has added the policy number as a key field, meaning that in order to update or delete a previously accepted record, the policy number will need to match the previous record. If the policy number changes, a delete record must be submitted followed by a new add record with the new policy number.


Retraction of Soft Error Code for Office Code/Site ID

Previously, CMS had indicated that several input errors will become “soft” errors beginning April 5, 2021. The error code CP03, which is triggered by an error in the Office Code/Site ID field, is no longer included among the “soft” error codes. As such, if this error code is returned, the record will not be accepted unless the RRE corrects the error and resubmits the record. CMS’s rationale for not accepting records with an error in the Office Code/Site ID field is that an error in this field could result in correspondence being sent to the wrong location.


Connect:Direct Reporting Method

CMS plans to discontinue the exchange of data via Connect:Direct to GHINY SNODE in April 2021. The User Guide provides for updated file naming conventions. The Connect:Direct method is not commonly used for reporting and was designed for RREs that have more than 24,000 records in one file submission on a regular basis. RREs that use this file transmission method should contact their EDI representative.


The User Guide is available at https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/NGHP-User-Guide/NGHP-User-Guide. If you have any questions about these changes to the User Guide or other Section 111 reporting issues, please let us know. We will be happy to help.


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