Purpose of the Webinar
On April 15, 2026, the Centers for Medicare & Medicaid Services (CMS) hosted a MMSEA Section 111 Mandatory Insurer Reporting Workers’ Compensation Medicare Set‑Aside (WCMSA) webinar. The session focused on Section 111 reporting requirements, with particular emphasis on the inclusion of WCMSA data within Total Payment Obligation to Claimant (TPOC) reporting. CMS indicated that the webinar was intended to address stakeholder questions and concerns following the implementation of these reporting requirements.
CMS Policy Background
CMS reiterated its obligation to protect the Medicare Trust Fund by ensuring that Medicare does not pay for services that should be covered by another insurer. To fulfill this obligation, CMS is authorized to collect data necessary to make accurate coordination‑of‑benefits determinations.
CMS explained that the inclusion of WCMSA data within TPOC reporting addresses a longstanding challenge, namely, that CMS previously lacked complete and consistent visibility into settlement medical allocations. This limitation impaired CMS’s ability to appropriately coordinate benefits and monitor compliance with Medicare Secondary Payer requirements.
Reporting Requirements and Guidance
CMS provided detailed guidance on:
- When Section 111 reporting is required
- Which specific data fields must be completed
- How WCMSA information should be submitted within the Section 111 reporting process
The guidance emphasized improving both the timeliness and accuracy of submitted data to reduce downstream issues and data conflicts.
CMS Use of WCMSA Data
CMS explained that Section 111 data feeds into the Common Working File (CWF), which is used to prevent Medicare from paying for medical claims related to a reported injury or condition that should be covered by another payer.
CMS additionally noted that it contacts Medicare beneficiaries directly regarding WCMSA attestation and exhaustion requirements. This outreach reflects increased scrutiny on ensuring WCMSAs are properly administered and exhausted prior to Medicare payment.
Reporting Scenarios and Common Issues
CMS reviewed multiple reporting examples and common challenges, including:
- Situations where Section 111‑reported MSA amounts do not align with amounts submitted through the voluntary WCMSA review process
- Clarification that Field 42 (Case Control Number) is voluntary, but failure to populate it may result in duplicate or multiple claims records
- Confirmation that Field 43 (Professional Administrator) is technically optional, but becomes mandatory when a professional administrator is engaged
CMS stressed that inaccurate or incomplete reporting across required data fields can create inconsistencies, lead to multiple files, and disrupt proper administration.
Professional Administrator EIN Clarification and Best Practice
CMS specifically clarified that the Professional Administrator EIN is not a required field. However, CMS emphasized that if the EIN is not entered correctly, the case will default to being treated as self‑administered within CMS systems.
CMS underscored the importance of accurate data entry and went as far as to present a case study in which the professional administrator EIN was zeroed out. In that example, despite professional administration being intended, the case was classified as self‑administered.
This highlights the need for clients to ensure that their internal teams and external vendors are correctly entering professional administrator information. Accurate EIN reporting is critical to ensuring a seamless settlement transition and avoiding unintended administrative or compliance issues.
Reporting Examples and Best Practices
CMS concluded by outlining several best practices, with particular emphasis on:
- Timely submission of Section 111 data
- Accuracy and completeness of all reported fields
- Consistency between Section 111 reporting and the voluntary WCMSA submission process
Recent CMS Guidance Updates Impacting MSP Compliance
In addition to the webinar discussion, CMS recently released updated guidance affecting Medicare Secondary Payer (MSP) compliance. On April 13, 2026, CMS published Version 4.5 of the Workers’ Compensation Medicare Set‑Aside (WCMSA) Reference Guide and Version 8.4 of the MMSEA Section 111 Medicare Secondary Payer Mandatory Reporting User Guide.
Key highlights from these updates are summarized below.
WCMSA Reference Guide Updates
Version 4.5 includes the following changes:
- Additional ZIP codes have been added to the table listing major medical centers (Appendix 7)
- The CDC Life Table link has been updated (Section 10.3)
MMSEA Section 111 NGHP User Guide Updates
Chapter I: Introduction and Overview
- Section 111 users may now submit requests to their EDI Representative online, in addition to using phone and email correspondence (Chapter 7 and Section 8.1)
Chapter II: Registration Procedures
- Section 111 users may submit requests to their EDI Representative online, expanding beyond traditional phone and email methods (Chapter 6 and Section 7.1)
Chapter III: Policy Guidance
- ORM termination requirements have been updated (Section 6.3.2)
- TPOC reporting guidance has been updated (Sections 6.4 and 6.5.1.2)
- Section 111 reporting requirements have been revised (Section 6.5.1.4)
- Guidance has been updated regarding submission of multiple records for a single individual (Section 6.5.1.3)
Chapter IV: Technical Information
- Section 111 users may now submit requests to their EDI Representative online (Chapter 12)
- The “as‑of” date has been removed due to implementation of new change reason codes (Table 7‑4)
- TPOC reporting guidance has been updated (Section 6.4)
Chapter V: Appendices
- No changes reported
At Ametros, we assist beneficiaries’ post-settlement with professional administration services. We proactively contact injury-related physicians and pharmacies to ensure they bill Ametros for injury-related care that would otherwise be covered by Medicare. This prevents unnecessary denials and potential post-settlement conditional payments from Medicare advantage and prescription drug plans.
If you have any questions about how Ametros simplifies and supports MSA administration and other future medical allocations post-settlement, don’t hesitate to get in touch with us.
