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What Are the Medicare Secondary Payer Reporting Requirements for Our Company’s Group Health Plans?


Are employer-provided health plans are subject to Medicare Secondary Payer (MSP) mandatory reporting requirements?

Certain insurers, TPAs, plan administrators, and fiduciaries must report information to CMS about individuals who are entitled to Medicare and covered under a group health plan. The purpose of the MSP mandatory reporting requirements (sometimes referred to as Section 111 reporting) is to help CMS determine whether a plan is primary to Medicare (that is, whether a plan pays first, and Medicare is a secondary payer).

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HHS Issues Updated Model Notices of Privacy Practices and Announces Part 2 Enforcement Program

HHS has updated its model Notice of Privacy Practices (NPP) materials to help covered entities and business associates comply with the Part 2 related NPP requirements that became enforceable on February 16, 2026.

02/26/2026

What Federal Mandates Apply to Our Company's Group Health Plan Other Than ERISA, COBRA, and HIPAA?

Many federal laws create mandates that may apply to your group health plan.

12/18/2025

IRS Guidance on Trump Accounts Addresses Cafeteria Plans and Employer Contributions, Announces Regulations on the Way

The IRS has announced that it intends to issue proposed regulations regarding Trump Accounts (TAs)

12/11/2025

Who Must Receive SPDs for ERISA Health and Welfare Plans?

QUESTION: We are reviewing the SPD procedures for our ERISA health and welfare plans and need some guidance. Who must receive SPDs for these plans?

12/02/2025

What Employees Are Counted for Purposes of COBRA’s Small Employer Exception?

QUESTION: We understand there is a small employer exception to COBRA for employers with fewer than 20 employees. What employees should we count for purposes of this exception?

12/02/2025