CMS Expands Section 111 Reporting to Include Voluntary WCMSA Data for Workers’ Compensation Claims

A major update to Medicare Secondary Payer (MSP) compliance has arrived in 2025. Effective April 4, the Centers for Medicare & Medicaid Services (CMS) now requires Responsible Reporting Entities (RREs) to report Workers’ Compensation Medicare Set-Aside (WCMSA) information through Section 111 reporting, when available. Although the submission of WCMSAs to CMS remains voluntary, this reporting expansion applies to all settlements with current Medicare beneficiaries, regardless of whether the MSA was submitted for CMS review or is evidence-based and non-submitted.

This change aims to improve the accuracy of CMS’ coordination of benefits and prevent Medicare from paying for medical services already covered by WCMSA funds. The information submitted will be integrated into the Common Working File (CWF) to support benefit coordination and notify Medicare beneficiaries of reporting details, which may lead to increased inquiries to claims adjusters and insurers.

CMS released guidance in User Guide Version 7.5 outlining seven new data fields, including MSA amount, payout structure, and coverage period. Incorrect reporting of key fields will result in hard errors that may trigger civil money penalties (CMPs) if not corrected in time. However, CMS will delay enforcement of penalties for WCMSA-related errors for two reporting periods following the implementation date.

Insurers, TPAs, and claim professionals should take this time to refine their data collection processes, ensuring all WCMSA data is reported accurately and timely. While the update does not affect the settlement terms or MSA validity, aligning reporting practices with CMS’ expectations is essential for compliance and avoiding penalties.