The Centers for Medicare & Medicaid Services (CMS) released Version 8.6 of its Section 111 Reporting User Guide on October 5, 2026. The five biggest changes phase out the NOINJ diagnosis code, add an alert after six months without a Claim Input File and clarify how to correct TPOC and WCMSA errors. CMS also clarified when wrongful death settlements must be reported and when a Qualified Settlement Fund (QSF) can report. 

Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) requires liability, no-fault and workers’ compensation payers to report claims involving Medicare beneficiaries to CMS. For insurers, third-party administrators (TPAs), and other Responsible Reporting Entities (RREs), understanding these changes can help prevent reporting errors and ensure that claims are handled in accordance with Medicare Secondary Payer (MSP) requirements. 

What Changed in Section 111 User Guide Version 8.6? 

Below are five key updates and what they mean for claims professionals. 

Update	Where to Find It	What RREs Should Do
NOINJ diagnosis code phased out	Chapter IV, Section 6.2.5.2	Identify valid ICD-10 codes for every claimed injury before the April 2027 hard error
Alert after six months with no Claim Input File	Chapters II and IV	Investigate each alert and confirm reporting is current
New TPOC and WCMSA correction steps	Chapters IV and V	Match the correction method to the error, effective April 2027
Wrongful death settlements	Chapter III, Section 6.5.1.4	Report unless documents and state law rule out medical expenses
QSF reporting exception	Chapter III, Section 6.5.1.8	Confirm every condition is met before a QSF reports

1. Is CMS Eliminating the NOINJ Diagnosis Code?

Yes. Per Chapter IV, Section 6.2.5.2, CMS is eliminating the use of the NOINJ diagnosis code, which was originally created for situations in which an RRE could not identify a diagnosis when reporting a settlement (Total Payment Obligation to Claimant, or TPOC).

Historically, the code was intended for limited circumstances involving claims without an alleged physical injury, such as certain loss-of-consortium claims, errors and omissions claims, directors and officers liability claims, and employment-related wrongful action claims.

CMS has clarified that settlements in which no injury is alleged that could lead to Medicare-covered items or services generally do not need to be reported on that basis. However, when an injury or illness has been claimed and released, the inability to identify the exact diagnosis code does not excuse the RRE from reporting the settlement.

What does the NOINJ change mean for claims professionals?

RREs should not rely on NOINJ as a substitute for identifying the injuries associated with a claim. Reporting teams should exercise appropriate due diligence to identify the applicable injuries and the valid ICD-10 diagnosis codes.

The guide identifies April 2027 as the effective date for the anticipated hard error that would cause a submission containing NOINJ to be rejected. RREs should review their reporting procedures and work with their reporting agents to prepare for this change.

2. What Happens If an RRE Submits No Claim Input File for Six Months?

Per Chapters II and IV of the guide, CMS will send a notification email to an RRE’s Authorized Representative and Account Manager when no Claim Input File has been submitted within the preceding six months.

A Claim Input File is the file an RRE submits to CMS containing the claim information required for Section 111 reporting.

What should an RRE do after an inactivity alert?

The notification is intended to alert the RRE that reporting activity may have stopped or been missed. However, an extended period without submission does not automatically mean the RRE has failed to meet its reporting obligations.

Upon receiving an alert, the RRE should investigate the reason for the inactivity. This may include confirming whether there were reportable claims, whether reporting activity was expected during that period, and whether the reporting process is operating as intended.

If the RRE uses an outside reporting agent, it should coordinate with that partner to determine whether any action is necessary.

Practical takeaway: RREs should establish a process for reviewing CMS notifications and confirming that their Section 111 reporting remains current, even during periods of low claims activity.

3. How Do RREs Correct TPOC and WCMSA Reporting Errors?

It depends on the error: erroneous TPOC information on a claim with accepted ORM requires a delete followed by an add, while a WCMSA reported in error requires an update, effective April 2027.

CMS has updated its instructions in Chapters IV and V of the User Guide for correcting previously accepted Total Payment Obligation to Claimant (TPOC) and Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) information in certain workers’ compensation and no-fault claims involving Ongoing Responsibility for Medicals (ORM).

TPOC generally refers to a settlement, judgment, award, or other payment that must be reported to CMS. ORM refers to an RRE’s ongoing responsibility to pay for medical care related to an injury. For background, see our recap of key changes to ORM termination and TPOC reporting.

The revised instructions address two situations, with the specified changes effective April 2027.

Situation 1: TPOC information was reported incorrectly.

If TPOC information was erroneously reported on a claim with previously reported and accepted ORM, and at least one TPOC date is on or after the ORM termination date, the RRE must send a delete record followed by an add record.

The delete removes the previously submitted record. The add then reports the required claim information without the erroneous TPOC values.

Situation 2: A WCMSA was reported in error.

If a TPOC 1 record and associated MSA information were previously reported and accepted, but the MSA was reported in error, the RRE must submit an update. The WCMSA fields must be populated with zeroes or spaces, as applicable. An auxiliary record should also be included if one was previously submitted and its information remains applicable. Our summary of the CMS webinar clarifying WCMSA reporting rules covers related requirements.

What does this mean for TPOC and WCMSA corrections?

The appropriate correction method depends on what was reported and what needs to be corrected. Simply changing a field to zero may not be sufficient in every situation.

For example, an indemnity settlement may have been reported while medical benefits remained open and an MSA was still under review. If the original reporting was premature or incorrect, the RRE must follow the applicable CMS correction procedure.

RREs should work with their Section 111 reporting teams or reporting agents to identify the appropriate action type and ensure that corrections follow CMS requirements.

Practical takeaway: Review the original submission and the nature of the error before correcting a record. The delete-and-add process and the update process are not interchangeable.

4. Do Wrongful Death Settlements Require Section 111 Reporting?

In most cases, yes. CMS has clarified its policy on reporting wrongful death settlements, judgments, and awards in Chapter III, Section 6.5.1.4 of the user guide.

In some states, medical expenses may be recoverable from wrongful death settlement proceeds. In addition, the language in a complaint or settlement agreement may release medical expenses, even when the parties did not specifically intend to do so.

As a result, CMS generally requires RREs to report wrongful death settlements unless they can definitively determine that the relevant documents and applicable state law and common law do not permit recovery of medical expenses from the payment and that medical expenses were not released, either expressly or in effect.

What does this mean for wrongful death claims?

A wrongful death settlement should not automatically be treated as exempt from Section 111 reporting simply because the claim involves a death rather than an injured claimant receiving ongoing medical treatment.

The RRE should evaluate the settlement language and applicable law to determine whether medical expenses may be recovered or have been released as part of the settlement.

When the answer is unclear, the parties may need legal guidance before deciding whether reporting is required.

Practical takeaway: Review the settlement documents and applicable law before concluding that a wrongful death settlement falls outside Section 111 reporting requirements.

5. When Can a Qualified Settlement Fund Report as the RRE?

Only under a narrow exception: the QSF must elect to report, be funded by two or more entities, have no active ORM, operate under Section 468B in connection with a bankruptcy proceeding, and have sole authority over paying claims.

CMS has revised its guidance in Chapter III, Section 6.5.1.8, concerning when a Qualified Settlement Fund (QSF) may serve as the RRE for Section 111 reporting purposes.

A QSF is a settlement fund established under Section 468B of the Internal Revenue Code. In certain complex settlements, multiple entities may contribute money to a fund that distributes settlement proceeds to multiple claimants.

Under the revised guidance, a QSF may be permitted to assume the RRE’s reporting role for qualifying TPOCs paid into the fund after October 1, 2011, when it would otherwise be impossible to determine precisely how much each contributing entity’s funds were allocated to each claimant.

This is a limited exception. The conditions include:

• The QSF elects to assume the RRE’s mandatory insurer reporting obligations.
• There is no active ORM.
• Two or more entities fund the QSF.
• The QSF operates under Section 468B of the Internal Revenue Code in connection with a state or federal bankruptcy proceeding.
• The QSF has sole responsibility for resolving and paying claims using the funds received and makes those decisions without review or approval by the entities that contributed the TPOCs.

An entity that contributes a TPOC but retains the right to adjudicate, review, or pay claims must report as an RRE and cannot rely on this exception.

CMS also retains a separate exception for qualifying TPOCs paid into a QSF before October 1, 2011, subject to the applicable conditions, including the absence of active ORM and the requirement that the funds were paid into the trust before that date.

What does the QSF exception mean for claims professionals?

The use of a QSF does not automatically transfer Section 111 reporting responsibility away from the entities that contributed settlement funds.

Before assuming that a QSF can report on behalf of the contributing entities, those entities should confirm that all applicable conditions are satisfied, including the QSF’s legal structure, its authority over claim resolution and payment, and the absence of retained decision-making rights.

Practical takeaway: Do not assume that a QSF eliminates an insurer’s or other RRE’s reporting obligations. Confirm that the specific arrangement qualifies for the CMS exception.

What Should RREs Do to Prepare for Version 8.6?

CMS’s Version 8.6 updates address both day-to-day reporting practices and more specialized settlement scenarios. RREs should consider taking the following steps:

• Review diagnosis coding procedures. Prepare for the elimination of NOINJ and confirm that appropriate diagnosis codes are identified when reporting is required.
• Monitor reporting activity. Establish a process for reviewing CMS notifications about periods without Claim Input File submissions.
• Review correction procedures. Ensure that reporting staff and reporting agents understand when to submit a delete followed by an add versus an update.
• Evaluate complex settlements carefully. Review wrongful death settlements and QSF arrangements before determining whether Section 111 reporting is required or an exception applies.
• Coordinate with your reporting partner. Confirm that applicable CMS changes are reflected in reporting procedures and that your team understands which changes require action and when.

Section 111 reporting requirements can be complex, particularly when a settlement involves unusual circumstances or previously submitted information needs to be corrected. Staying informed about CMS guidance and maintaining a reliable reporting process can help RREs manage their Medicare Secondary Payer compliance responsibilities.

Frequently Asked Questions About Section 111 User Guide Version 8.6

What is the CMS NGHP Section 111 User Guide?

It is the CMS manual that explains how Responsible Reporting Entities report liability, no-fault and workers’ compensation claims involving Medicare beneficiaries. CMS updates it several times a year. Version 8.6 was released on October 5, 2026. Tower’s Section 111 services help RREs keep up with each update.

When does Section 111 User Guide Version 8.6 take effect?

CMS released Version 8.6 on October 5, 2026. The NOINJ hard error and the new TPOC and WCMSA correction steps take effect in April 2027. The wrongful death and QSF clarifications are part of the current guide.

Who has to report under Section 111?

Responsible Reporting Entities (RREs) must report. These include liability insurers, self-insured entities, no-fault insurers and workers’ compensation carriers. Many RREs use a Section 111 reporting agent or TPA to submit files, but the RRE stays responsible for compliance.

When will CMS reject Section 111 files that use NOINJ?

The technical chapter of the guide identifies April 2027 as the effective date for a hard error on NOINJ. After that, a submission containing NOINJ would be rejected. RREs should review their coding procedures before then, and a Section 111 audit can flag claims that still rely on NOINJ.

Does a six-month gap in Claim Input Files mean an RRE is out of compliance?

Not on its own. CMS will send an alert after six months without a Claim Input File, but a gap can happen when there are no reportable claims. The RRE should investigate the alert and confirm its reporting is current.

Are wrongful death settlements exempt from Section 111 reporting?

Generally, no. CMS policy guidance expects RREs to report wrongful death settlements unless they can confirm medical expenses cannot be recovered and were not released. Review the settlement documents and state law first. Our liability settlement solutions can help with complex cases.

What happens if an RRE misses Section 111 reporting requirements?

CMS can impose civil money penalties for Section 111 reporting failures. Learn more in our key takeaways from the CMS webinar on civil money penalties.

Need Help With Section 111 Reporting?

Tower MSA Partners’ Section 111 reporting and Section 111 audit services help RREs catch errors and stay compliant as CMS rules change. If you have questions about these updates or your Section 111 reporting obligations, contact Tower MSA Partners’ Chief Compliance Officer, Dan Anders, at daniel.anders@towermsa.com, or reach our team through the contact page.