The April 2025 Section 111 Expansion: A Practitioner's Reference for the New WCMSA Reporting Fields

For Total Payment Obligation to the Claimant (TPOC) dates on or after April 4, 2025, Responsible Reporting Entities (RREs) must transmit Workers' Compensation Medicare Set-Aside Arrangement (WCMSA) data through the Section 111 Non-Group Health Plan (NGHP) Claim Input File. The change adds seven dedicated fields to the Claim Input File layout, repurposes a block previously reserved for future use, and introduces a new family of "CW" error codes that can reject otherwise-timely TPOC submissions. The expansion is the most consequential modification to NGHP reporting since the inception of mandatory insurer reporting under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act (MMSEA).

This reference is written for the people doing the work: compliance analysts, claims operations leads, defense counsel coordinating settlement reporting, professional administrators, and MSA preparation shops feeding data downstream to RREs. It walks the seven new fields, the populations subject to reporting, the practical impact of the Professional Administrator EIN element on the administration market, common reporting failures, and a worked example showing how a $400,000 WCMSA flows through the file today versus before April 4, 2025.

What Changed and Why

CMS announced in late 2023 that it intended to capture WCMSA data through the existing Section 111 reporting infrastructure rather than build a parallel intake. The agency's stated purpose is improved coordination of benefits: when a Medicare beneficiary presents for treatment that may be related to a settled work injury, the Common Working File (CWF) needs to know an MSA exists, how large it is, what period it covers, and who administers it. Without that data, Medicare cannot reliably deny payment for items that should be paid from MSA funds, and the agency cannot enforce the secondary payer rules that justify the MSA in the first place.

The reporting requirement applies prospectively. Records with a TPOC date on or after April 4, 2025 are subject to the new edits. Settlements with earlier TPOC dates remain governed by the prior file layout, even if reported after April 4, 2025. CMS opened a test environment for the new fields beginning October 7, 2024, allowing RREs to validate file generation before production cutover.

CMS has stated that civil money penalties (CMPs) for hard-error rejections tied to the new fields will not be imposed for two reporting periods following the April 4, 2025 implementation date. That grace period does not relieve RREs of the underlying reporting obligation; it only defers the penalty exposure for editing errors.

The Seven New Fields

The new fields occupy positions previously labeled "Reserved for Future Use" inside what was formerly a single field 37 in the Claim Input File. After the expansion the WCMSA elements occupy fields 37 through 43, and a smaller residual filler block now sits in field 44. All subsequent fields have been renumbered. RREs and their reporting agents must update their file generation logic accordingly; the shift is not cosmetic.

Field 37 — MSA Amount

The total dollar value of the MSA, reported as either $0 or an amount greater than $0. For structured settlements the value reported is the total payout, not the present value or the up-front cost of the annuity. This distinction matters: a structured MSA with a $250,000 initial deposit and twenty years of $15,000 anniversary deposits has an MSA Amount of $550,000 ($250,000 + 20 × $15,000), not $250,000.

Reporting is required even when no MSA is funded as part of the settlement. In that case the field is populated as $0. CMS has separately stated that it reserves the right to audit $0 reported values where it suspects cost-shifting to Medicare.

Field 38 — MSA Period

If the MSA Amount is greater than $0, the number of years the MSA is expected to cover the beneficiary. The period is generally derived from the rated-age computation or, where no rated age is used, the beneficiary's life expectancy at settlement. The field is integer-valued and tied directly to the allocation methodology in the underlying MSA report. For $0 MSAs, the field is left empty.

Field 39 — Lump Sum or Structured/Annuity Payout Indicator

A single-character flag: "L" for a lump-sum MSA, "S" for a structured/annuity MSA. The indicator drives downstream conditional logic on fields 40 and 41.

Field 40 — Initial Deposit Amount

If the MSA is a structured annuity (Field 39 = "S"), the initial deposit amount funded at settlement before the first anniversary deposit. For lump-sum MSAs, the field is empty.

Field 41 — Anniversary (Annual) Deposit Amount

If the MSA is a structured annuity, the recurring annual deposit funded each anniversary year following the initial deposit. The combination of fields 40 and 41 must reconcile to Field 37 across the period in Field 38: Initial Deposit + (Anniversary Deposit × (Period − 1)) should equal the MSA Amount, subject to standard rounding.

Field 42 — Case Control Number

If CMS reviewed and approved the WCMSA, the Case Control Number assigned by the Workers' Compensation Review Contractor (WCRC). The field is optional; many submitted WCMSAs (particularly those below the $25,000 review threshold or otherwise not voluntarily submitted) will not have one. After July 17, 2025, $0 WCMSAs will not generate Case Control Numbers because CMS no longer reviews them — see our companion guide on the end of $0 WCMSA proposals.

Field 43 — Professional Administrator EIN

The Employer Identification Number of the professional administrator, if one has been retained. The field is technically optional, but its operational consequences are not. CMS has stated that if Field 43 is left blank, or if the EIN does not match a registered administrator account in the Workers' Compensation Medicare Set-Aside Portal (WCMSAP), the case administrator defaults to the beneficiary. The MSA is then treated by CMS systems as self-administered, regardless of any actual professional administration arrangement on the ground.

The downstream effect: CMS will direct beneficiary correspondence (annual attestations, balance reconciliations, exhaustion notices) to the claimant rather than the professional administrator. This produces predictable confusion — beneficiaries who do not know what to do with an attestation form, administrators who learn after the fact that CMS has been writing to the wrong person, and disputes about whether the MSA was administered consistently with CMS's expectations.

Reporting Population: Who Must File

Reporting falls on the RRE, which for workers' compensation TPOCs is generally the carrier or self-insured employer. The RRE may use a reporting agent, but the obligation does not transfer. The MSA-data fields apply to:

• Workers' compensation settlements with a TPOC date on or after April 4, 2025
• Where the claimant is a Medicare beneficiary or has a reasonable expectation of Medicare entitlement within 30 months of settlement
• Where the TPOC meets the existing reporting threshold (currently settlements above $750)

Reporting is required whether or not the MSA was submitted to CMS for review. The pre-April 4 distinction between "submitted" and "non-submitted" MSAs collapses at the Section 111 layer: CMS expects to know about every MSA that funds a settlement, and about every settlement that does not fund one (reported as $0). Self-administered MSAs are reported with Field 43 left blank. Professionally administered MSAs report the administrator EIN.

For settlements that include both ongoing responsibility for medicals (ORM) and a TPOC with an MSA, the WCMSA fields attach to the TPOC record. The Event Table in Chapter IV of the NGHP User Guide has been updated with new scenarios for correcting MSA data — most corrections require a delete-and-add sequence rather than an in-place update, with the exception of MSA Amount and MSA Period changes, which can be sent as updates.

The Professional Administrator EIN Field: Market Implications

Field 43 is technically optional, but it is the most consequential of the seven new elements for the administration market.

Before April 4, 2025, professional administration was a private contractual arrangement between the claimant and the administrator. CMS had no systematic visibility into which MSAs were professionally administered and which were not. The new field changes that. Every WCMSA reported through Section 111 now carries either an EIN that ties it to a registered WCMSAP administrator account, or it does not — and absence is read as self-administration.

Three near-term consequences follow.

First, professional administrators have a strong operational reason to ensure their EIN is registered in the WCMSAP and supplied to the RRE before the TPOC report goes out. Administrators acquired post-settlement, or onboarded after the Section 111 file has been transmitted, face a delete-and-add sequence to correct the record. The cleanest workflow puts the administration decision and the EIN handoff inside the settlement timeline, not after.

Second, defense counsel and settlement planners need to add Field 43 to their settlement-checklist artifacts. The administration decision is no longer a downstream operational matter; it is now a Section 111 reporting input that must be locked in before the RRE files. A claimant who plans to use a professional administrator but has not yet selected one at TPOC will be reported as self-administered by default.

Third, the data CMS now collects through Field 43 produces, over time, a federal-level view of the professional administration market: which administrators are managing how many cases, with what aggregate balances. The agency has not announced an intent to publish this data, but the data will exist.

Common Reporting Errors and Edits

CMS introduced a new family of error codes prefixed "CW" in the Claim Response File Error Code Resolution Table (Appendix G of NGHP User Guide Chapter IV). Each "CW" code maps to one of the new fields. All fields except Field 43 generate hard errors when populated incorrectly — meaning the entire TPOC record is rejected. The most frequent error patterns observed in the testing window and in early production reporting:

Reporting MSA Amount as the present value of an annuity rather than the total payout. This is the single most common methodological error. The instruction is unambiguous in the NGHP User Guide: report the total payout for structured MSAs. RREs whose source data comes from settlement documents drafted with present-value language are particularly exposed.

Mismatched annuity arithmetic. Initial Deposit + (Anniversary Deposit × (Period − 1)) must reconcile to MSA Amount. Off-by-one errors on the period — counting the initial deposit year as one of the anniversary years, or vice versa — produce arithmetic that fails CMS edits and rejects the file.

Empty Field 38 (MSA Period) when MSA Amount is greater than $0. Conditional-required fields are a frequent source of file generation bugs in RRE systems that previously had no reason to capture MSA period.

Unregistered Professional Administrator EIN in Field 43. Field 43 itself is a soft edit, but a non-matching EIN silently routes the case to default self-administration. Compliance teams who track only hard-error rejections will not see this failure mode in their error logs.

Reporting MSA data on TPOCs that pre-date April 4, 2025. The new fields apply only to TPOC dates on or after the implementation date. Reporting agents that have applied the new layout indiscriminately produce edit failures on legacy settlements.

Failing to delete-and-add when MSA structure changes. If the lump-sum versus annuity structure changes after initial reporting, the Event Table requires a delete record followed by a new add record. A simple update transaction will not propagate the change correctly.

The CMP grace period (two reporting quarters following implementation) defers penalties but does not defer the editing errors themselves. RREs that accumulate large rejected-record backlogs during the grace period inherit a substantial cleanup obligation when penalties resume.

Worked Example: A $400,000 WCMSA Through Section 111

Consider a hypothetical workers' compensation settlement: claimant is a 58-year-old Medicare beneficiary, settling a low-back injury for a $1.2 million TPOC, with a $400,000 WCMSA inside the settlement. Rated age is 65; MSA period is 22 years. The MSA is structured as an annuity with a $52,000 initial deposit and $16,571 anniversary deposits for 21 years. The claimant has retained a professional administrator with EIN 12-3456789, registered in the WCMSAP. The case received CMS approval; Case Control Number is 2025-XXXX [example only].

Pre-April 4, 2025 reporting

Fields 37–43 do not exist. The TPOC record carries the settlement amount, ORM indicators, ICD codes, and standard claimant and RRE identifiers. Section 111 conveys the settlement happened; nothing in the file tells CMS an MSA exists, how it is structured, or who administers it. CMS learns about the MSA, if at all, through the parallel WCMSAP submission for review, or not at all if the case was below the review threshold or otherwise unsubmitted.

Post-April 4, 2025 reporting

The same TPOC carries seven additional populated fields:

Field	Value
37 — MSA Amount	$400,000
38 — MSA Period	22
39 — Lump/Annuity Indicator	S
40 — Initial Deposit	$52,000
41 — Anniversary Deposit	$16,571
42 — Case Control Number	2025-XXXX
43 — Professional Administrator EIN	12-3456789

Arithmetic check: $52,000 + (21 × $16,571) = $52,000 + $347,991 = $399,991, which rounds to $400,000 within standard reporting tolerance. The structure is internally consistent and the file passes CMS edits. The Common Working File flags the claimant's record with a "W" indicator, alerting the Medicare Administrative Contractor to deny work-injury-related billing for items that should be paid from MSA funds. Beneficiary correspondence is routed to the registered professional administrator, not the claimant.

If the same case had been reported with Field 43 blank, the claimant would have received CMS attestation correspondence directly — a workflow no professional administrator wants in production.

Practical Implications for Defense Counsel, MSA Shops, and Professional Administrators

For defense counsel and settlement planners. The MSA structure must be locked in at TPOC, not after. Late-stage changes — switching from lump sum to annuity, changing the administrator, adjusting the period — now have Section 111 reporting consequences. Settlement checklists should add a Section 111 reporting block alongside the standard MSA approval and funding instructions. The Field 43 administrator decision is not optional from an operational perspective even though it is technically optional from a reporting perspective.

For MSA preparation shops. The data deliverable to the RRE must be machine-readable and reporting-aligned. A PDF MSA report alone is insufficient: the RRE needs MSA Amount, MSA Period, lump/annuity indicator, initial deposit, anniversary deposit, Case Control Number (when applicable), and administrator EIN extractable into their Section 111 file generation pipeline. Shops that hand off only narrative reports place the burden of data extraction on the carrier's compliance team and increase rejection risk.

For professional administrators. EIN registration in the WCMSAP is now load-bearing. Administrators who onboard cases without confirming their EIN is registered, and that the RRE has the correct EIN before TPOC reporting, will see a portion of their book reported as self-administered. This is correctable, but the correction requires coordination with the RRE that originated the report.

For carriers and self-insured employers (RREs). File generation logic must validate the new fields before transmission. The CMP grace period is a runway, not a reprieve; rejected records accumulate liability that materializes when the grace period ends.

Sources

• Workers' Compensation Medicare Set-Aside Arrangements — CMS
• Section 111 NGHP User Guide — CMS landing page
• WCMSA Reference Guide v4.5 (April 13, 2026 PDF)
• What's New — Workers' Compensation Medicare Set-Aside Arrangements (CMS)
• What's New — NGHP Section 111 (CMS) — version history and recent updates
• NGHP User Guide Chapter IV (Technical Information) v8.2 — October 6, 2025 (CMS PDF) — Appendix A (Claim Input File Detail Record), Appendix G (Error Code Resolution Table); the April 2025 Section 111 expansion was introduced in v8.0, refined in v8.1 (May 5, 2025) and v8.2 (October 6, 2025), and is the operative requirement set in current v8.4 (April 13, 2026)

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If your team is building Section 111-aligned MSA deliverables and needs a reporting-ready data package alongside the narrative report, see how Zicron AI prepares WCMSAs at zicron.claims/msa. A redacted sample MSA showing the reporting-ready data block is available at zicron.claims/msa/sample.