Medicare Secondary Payer News, Notes, and Updates for 2025

In its October 2023 Final Rule on MMSEA §111 reporting, CMS acknowledged that, beyond established thresholds, it may recognize additional reporting exclusions that negate the obligation to report certain settlements involving Medicare beneficiaries. Subsequent updates to the NGHP User Guide—particularly Version 7.4—reinforce that CMS retains discretion to grant reporting extensions, exemptions, or alternative processes that it deems sufficient to satisfy Section 111 requirements. Later User Guide revisions further clarified key exclusions, confirmed reporting thresholds, and expanded guidance on workers’ compensation settlements and Medicare set-aside arrangements, underscoring CMS’s evolving and more nuanced approach to reporting obligations and civil money penalties.