Section 111 GHP Reporting
Group health plan (GHP) RREs must report to CMS information about Medicare-eligible individuals who are covered by the GHP as active employees or dependents of active employees. This allows CMS to determine when the GHP is primary and Medicare is secondary. GHP reporting is submitted quarterly through the COBSW portal.
Reporting Process
- Register as an RRE with CMS through the COBSW portal
- Submit quarterly input files with Medicare-eligible employee and dependent information
- Receive response files from CMS confirming Medicare eligibility
- Update coordination of benefits based on CMS response files
- Maintain records of all Section 111 submissions and responses
Delegation to TPA
IQ Insight
Most self-funded employers delegate Section 111 reporting to their TPA. The TPA registers as the RRE on behalf of the employer and submits quarterly reports. Confirm your TPA is registered as an RRE and is submitting quarterly reports. Obtain written confirmation of submission for each quarter. The employer remains responsible for Section 111 compliance even if the TPA fails to report.