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Section 111 of the MMSEA (Medicare, Medicaid and SCHIP Extension Act of 2007) will require the providers of group health plans, liability insurance (including self-insurance), no fault insurance and workers’ compensation insurance to determine the Medicare-entitlement of all claimants and report certain information about those claims to the Secretary of Health and Human Services. With the objective of assisting the Secretary with coordinating benefits and uncovering potential reimbursement claims, this recent legislation reinforces the intent of ensuring Medicare is treated as the payer of last resort. The penalty for non-compliance is $1,000 per day for each day the responsible party is out of compliance. This penalty is in addition to other fines that defendants can be fined if Medicare’s reimbursement claim is ignored in any settlement. The new rules will apply to settlements on or after Jan 1, 2009 for group health plans and on or after July 1, 2009 for liability insurance (including self-insurance), no fault insurance and workers’ compensation insurance. For more information about Section 111 reporting, please visit https://www.cms.gov/MandatoryInsRep.

iSpace currently works with multiple clients and helps them through the process of complying with MMSEA Section 111 mandatory reporting. iSpace consulting practice works with clients from registration all the way through reporting. iSpace has subject matter experts that can guide and help your company become compliant. iSpace has developed a proprietary reporting platform which helps its client meet the requirements of MSP reporting. For more information about how we can assist you, please review the following links or contact us via the Request for Information & Demo.  

  • iSpace MSP Reporting Services
  • iSpace MSP Application Features & Functionality


iSpace has developed a proprietary reporting platform that can help you be compliant with the mandatory reporting.

iSpace consulting & technology practice currently works with multiple clients on their regulatory state, federal and CMS reporting needs. Specific to MMSEA Section 111, iSpace can help you in the following areas:

  • Administrative: Responsible Reporting Entities (RREs) must register with COBC and provide notification to the COBC of their intent to report data in compliance with the requirements of Section 111 of the MMSEA. Registration by the RRE must be completed before testing can begin.
    Through this registration process, the COBC will obtain the information needed to
    • Certify the registrant is a valid RRE for Section 111
    • Assign a Section 111 Reporter ID to each RRE
    • Develop a Section 111 reporting profile for each RRE, including estimates of the volume and type of data to be exchanged for planning purposes
    • Assign a production live date and file submission timeframe to each RRE
    • Establish the necessary file transfer mechanisms, and
    • Assign a COBC Electronic Data Interchange Representative (EDI Rep) to each RRE to assist with ongoing communication.
    Timeframe for registration is as follows:
    • New Section 111 GHP RREs will register on the COBSW starting on April 1, 2009
    • Former GHP VDSA/VDEA partners who have already registered for Section 111 using the paper form, will also complete the account set up steps on the COBSW starting on April 1, 2009. However, the data provided previously will be pre-loaded.
    • Liability insurance (including self-insurance), no-fault insurance and workers’ compensation RREs will register on the COBSW starting on May 1, 2009.

Note:  GHP reporters should have registered in April 2009.  However, COBC accepts new registrations till date but when the new GHP reporters submit production data, they may be penalties levied by CMS at their discretion for being late.   GHP reporters who already have registered a while back and have now started sending the production files may also be subjected to late submission penalties.

iSpace can work with the RRE or the Agent and guide them through the registration and data testing process.

  • Infrastructure: iSpace has developed a robust reporting engine to transmit and receive data to and from regulatory bodies. The engine can be customized by clients and their customers to transmit data (MSP input file), receive data back (MSP response file), receive error files, correct errors and maintain a history (MSP occurrences) and audit trail. The engine generates standard reports to keep track of all reports, errors and history. iSpace provides this reporting engine on a licensing or ASP model.
  • Process & System: iSpace will work with clients and help support their quarterly reporting based on COBC established reporting time frames.
  • Why iSpace: CMS is still working on the formalities and formats related to mandatory reporting. Depending on if you are an RRE or an Agent, the work load and maintenance of an application could take up the time and focus of multiple employees. Once you have an application and are reporting, you will still need to manage CMS expectation on an ongoing basis. iSpace can bring down the total spend on MMSEA Section 111 mandatory reporting without loss of quality or attention to detail.
For more information about our services, reporting platform/application or a demo, please click here – Request for Information


  • Robust, secure online application built on n-tier architecture
  • Secure login Agents, RRE and Admin’s
  • Ability to accept data from clients in multiple formats – Excel to XML and everything in between
  • Robust database that maintains history of all transactions to eliminate errors and duplicates
  • Configurable validation engine to validate data against user defined rules
  • Transformation engine configured to format data to COBC format
  • COBC output format pre-configured
  • Secure and encrypted data transmission
  • Ability to track MSP response files from CMS and track MSP occurences and errors
  • Online access for fixing validation errors and errors on MSP response file
  • Agents have admin capabilities and can control client login
  • Scheduler to alert and remind clients on data transmission
  • Application hosted in a hardened co-lo facility with 100% uptime
  • Support available to cater to client needs and changes
  • HIPAA compliant
  • Application available on license or ASP
  • Low cost of ownership and maintenance
  • Ongoing support to make changes to updates from CMS

For more information about our services, reporting platform/application or a demo, please click here – Request for Information


While iSpace makes every effort to keep the information on this web site accurate, we make no warranty or representation, express or implied about its accuracy, completeness or appropriateness for a particular purpose. Thus you assume full responsibility for using the information at this web site, and you understand and agree that neither iSpace nor any of its employees is responsible or liable for any claim, loss or damage resulting from its use. iSpace does not intend the above information to substitute for official updates and announcements by CMS. For the latest information about changes and updates to MMSEA Section 111, please visit https://www.cms.gov/MandatoryInsRep. The information provided using this Web site is only intended to be general summary information to our clients. It is not intended to take the place of either the written law or regulations. iSpace tries to ensure that the information in this web site is correct but does not accept liability for errors and omissions. The content of this website is for general information purposes only and does not constitute advice.

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