Section 111 Rulemaking Set for Release December 2019; LMSA Rulemaking Set for Release February 2020
Heather Sanderson
November 21, 2019

We have previously blogged regarding two Notice of Proposed Rulemakings (NPRMs) regarding Section 111 Civil Monetary Penalties and MSP and Future Medicals (which will propose options for LMSAs and/or protecting Medicare’s future interest in General Liability claims) pending on the Office of Management and Budget (OMB)’s website. Our prior blog on the Section 111 rulemaking can be found here and our prior blog on MSP and Future Medicals can be found here.

Just recently, the release date was updated on both. The Section 111 rulemaking is now set for release December 2019, and the MSP and Future Medicals/LMSA rulemaking is now pushed out to February 2020.  It appears that CMS is serious about releasing the Section 111 rulemaking this year, as we are also aware that the Proposed Rule has already been drafted and is currently pending review at the White House/OIRA. We recommend that Responsible Reporting Entities (RREs) take proactive steps now to ensure compliant reporting, and we will keep our subscribers posted once the NPRM and the LMSA NPRM is released. Contact us at with any questions.