“CMS’ Delayed Enforcement of Civil Monetary Penalties Provides More Time for Medicare Compliance” 

WorkersCompensation.com
05.05.2026

Swift Currie attorney, Jeff Stinson, authored an article for WorkersCompensation.com discussing how the CMS recently delayed the penalty provisions associated with failure to adequately prepare Section 111 reporting requirements for carriers in workers’ compensation claims. Importantly, those who handle workers’ compensation claims on the carrier or defense side have limited time to get their compliance up to speed, or they risk significant penalties. 

Responsible reporting entities (RREs) – including insurance carriers, self-insured employers and third-party administrators – have until July 1, 2026 to ensure both Section 111 reporting is in order and have seven additional pieces of data documented for any settlement (TPOC) involving a Medicare beneficiary that closes out the medical portion of a claim and exceeds $750.

“CMS has given RREs nearly a year of a lifeline from its original plan to start issuing penalties to ensure that compliance is up to speed,” said Stinson. “There is still time to ensure full compliance by July 2026, but RREs need to be prepared to face stiff and escalating penalties if they fail to get their Medicare house of cards in order soon.”

To view the full article, you may click here.

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