Prepare for April 2025 WCMSA Compliance with SandersonComply: Your Solution for Section 111 Reporting

As many readers are likely aware, the Centers for Medicare & Medicaid Services (CMS) will expand Section 111 Total Payment Obligation to Claimant (TPOC) reporting to include Workers’ Compensation Medicare Set-Aside (WCMSA) information commencing April 4, 2025. Non-Group Health Plan (NGHP) Responsible Reporting Entities (RREs) settling workers’ compensation claims involving Medicare beneficiaries will soon be required to report the following WCMSA data to CMS through TPOC reporting:

• WCMSA Amount

• WCMSA Period

• Lump Sum / Annuity Indicator

• Initial Deposit Amount (if annuitized)

• Anniversary (Annual) Deposit Amount (if annuitized)

• Case Control Number (if WCMSA has been submitted)

• Professional Administrator EIN (if WCMSA will be professionally administered)

It is imperative that RREs are prepared for WCMSA reporting by April 4, 2025, as failure to properly report these WCMSA fields may result in a “hard error” (rejected Section 111 reporting record), causing significant exposure to civil money penalties.

Sanderson Firm’s reporting solution, SandersonComply, is already updated and equipped for proper reporting of WCMSA information to CMS and is now available for all NGHP RREs. SandersonComply provides our NGHP RRE clients with a purpose-built, user-friendly reporting solution for accurate and timely Section 111 reporting compliance, and it includes benefits such as data pre-validation, EDI and API data integration, and automated file submissions.

NGHP RRE testing of the upcoming WCMSA fields began on October 7, 2024. If your organization is experiencing testing concerns or would simply prefer to learn more about how SandersonComply will satisfy all of CMS’ Section 111 compliance requirements, please contact us.