Health Benefits Compliance
Medicare Secondary Payer (MSP) Section 111 Reporting
Employer Guide
Most employers are not responsible for filing Section 111 reports directly, but they should understand who is responsible and cooperate with required information requests from carriers, TPAs, PBMs, or other reporting vendors and oversee the reporting process to ensure required filings are submitted.
What Is Section 111 Reporting?
Section 111 reporting is part of the Medicare Secondary Payer (MSP) rules. It requires certain entities to provide information to the Centers for Medicare & Medicaid Services (CMS) about individuals who have group health plan coverage and may also be entitled to (enrolled in) Medicare.
The purpose of the reporting is to help CMS determine when a group health plan should pay claims before Medicare and to prevent Medicare from paying claims that should have been paid by another source first.
Failure to comply with Section 111 reporting requirements can result in significant civil penalties (for example, as of this writing, $368-$1,512 per day per record, to a maximum of $365,000 per violation).
Why Employers Should Care
Although most employers are not responsible for actually submitting Section 111 reports, employers play an important role in supporting the reporting process.
Employers are often asked to provide information needed by carriers, third-party administrators (TPAs), or other reporting vendors, including:
- Employee eligibility and enrollment data
- Medicare-related information
- Employee counts used for MSP determinations
- Information regarding covered spouses and dependents
- Details regarding plan design and coverage
Providing accurate and timely information helps ensure reporting is completed correctly and reduces compliance risk.
August 2025
This document is not intended to be exhaustive, nor should any information be construed as tax or legal advice.
