Days Away from the Section 111 Civil Money Penalties Final Rule?

September 29, 2023
The Centers for Medicare & Medicaid Services (CMS) appear poised to release a long-awaited final rule related to MMSEA Section 111 reporting civil money penalties.  Earlier this month, the Office of Management and Budget concluded the regulatory work and it now appears that a final rule will be published shortly (pending a possible government shutdown).  

As this final rule poses a substantial financial impact to payers, upon its release, our compliance and Section 111 teams will provide a review and analysis of the rules and associated penalties to help you assess any associated risk to your program.

Our goal is to keep you informed with Accurate, Complete and Timely (ACT) information. Please stay alert and take advantage of the following communications.

  • ECS will send direct email notifications as information is made available.
  • ECS will post a detailed Blog once CMS publishes the Section 111 Civil Money Penalties Final Rule.
  • ECS will host a webinar within 3 days of the Final Rule being published to review the rule and the impact to the industry.
  • ECS has established a dedicated email address to confidentially receive and respond to your questions regarding the risk to your program:

In addition to keeping you informed, ECS can help mitigate your MSP compliance risk. ECS has compliance assessment and audits that can identify and address MSP compliance issues at the claim file level, program level and upon receipt of a demand for Civil Money Penalties. For more information on our services, please contact your Regional Compliance Consultant or email us at

For more information regarding the Section 111 Civil Money Penalties, please reference our previous blogs:






ECS monitors CMS Medicare Secondary Payer matters closely, and we will certainly keep you apprised of additional developments. Should you have any questions please contact Marty Cassavoy at 781-517-8085 or

Marty Cassavoy

Marty Cassavoy

Marty Cassavoy is the Sr. Vice President of MSP Compliance and Business Development at ExamWorks Compliance Solutions. Marty and his team develop solutions for challenges in all areas of Medicare Secondary Payer compliance and across all insurance types. An attorney licensed to practice law in Massachusetts, Marty works out of ExamWorks’ Woburn, Massachusetts office and can be reached at 781-517-8085 or