Important NGHP Section 111 Guide Updates & How to Ensure Full Compliance

CMS has released an updated version of the NGHP Section 111 User Guide, introducing critical clarifications and new requirements that impact reporting. Staying ahead of these changes is essential to avoid compliance risks and potential penalties.

Below is a summary of the most significant updates that require your immediate attention.

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Key Highlights from the Latest NGHP User Guide:

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• Complex Settlement Reporting (Ch. 3): New, detailed guidance clarifies how to report a single settlement (TPOC) or Medicare Set-Aside (MSA) that resolves multiple claims with different Dates of Incident (DOI). You must now report the earliest DOI and include all diagnosis codes, a significant shift in reporting practice.
• New Data Requirement (Ch. 5): Submitting a Recovery Agent Tax Identification Number (TIN) is now mandatory if a Recovery Agent Name is provided. This requires immediate action to collect TINs from all relevant partners.
• Technical Changes: Updates include corrected response file timelines and new unsolicited response reason codes coming in April 2026.

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Link to the New CMS User Guide: https://www.cms.gov/medicare/coordination-benefits-recovery/mandatory-insurer-reporting/whats-new

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Navigate These Changes with Confidence Using KAboodle

These updates add new layers of complexity to an already challenging compliance process. Manual tracking and reporting increase the risk of errors that could lead to Civil Monetary Penalties (CMPs) from CMS.

This is where KAboodle, our proprietary SaaS compliance platform, becomes your most valuable asset. KAboodle is engineered to automatically adapt to these regulatory changes, ensuring your reporting is always accurate and up-to-date.

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• Guided Workflows: KAboodle simplifies complex scenarios, like multi-incident settlements, ensuring you apply the new CMS rules correctly every time.
• Data Integrity Checks: Our system enforces new requirements, like the Recovery Agent TIN field, preventing errors before submission.
• Audit-Ready Trail: Maintain a complete and organized record of all your reporting activities.

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Go Beyond Software: Gain Full Indemnification

Technology is powerful, but peace of mind is priceless. That’s why Allan Koba Compliance Solutions offers full indemnification from Civil Monetary Penalties for any settlement reported through our KAboodle platform and managed by our team.

When you partner with us, you’re not just buying software—you’re transferring your compliance risk. We stand behind our work with a guarantee that protects your organization.

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Next Steps

Don’t let evolving regulations become a liability.

• Review the new CMS guide using the link above.
• Schedule a brief 15-minute call with our experts to discuss how these changes specifically impact your operations.
• Discover KAboodle and learn how our technology and indemnification guarantee can safeguard your organization.

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Email info@allankoba.com today to set up a meeting.  

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Thank you for your trust in Allan Koba Compliance Solutions.