CMS Updates NGHP User Guide & 2026 Reminders
by F. Fairchok
The Centers for Medicare & Medicaid Services (CMS) released an update to the Non-Group Health Plan (NGHP) Section 111 Reporting User Guide on January 5, 2026. The User Guide, Version 8.3, contains minimal updates and it appears that the normal notification process was not used to alert the industry to the changes.
The first update (in Chapter I, Chapter II and Chapter IV) pertains to what will be provided when matching a Medicare beneficiary and states that “Verbiage has been added to clarify that a member’s most current Medicare ID will be provided when a match is found.” The Guide further clarifies that “On the query response record, the BCRC will provide information on whether the individual has been identified as a Medicare beneficiary based upon the information submitted and if so, provide the most current Medicare ID (and other updated information for the individual) found on the Medicare Beneficiary Database (MBD).”
The second update (in Chapter III) brings the Guide up to date with the previously announced threshold stating, “As of January 1, 2026, CMS will maintain the $750 threshold for no-fault insurance, where the no-fault insurer does not otherwise have ongoing responsibility for medicals (Sections 6.4.2, 6.4.3, and 6.4.4).”
Reminder: Civil Money Penalties Webinar
CMS will host a webinar for Civil Money Penalties relating to Non-Group Health Plan reporting on Thursday, January 15, 2026 at 1:00 PM Eastern time. Please read our recent blog for further details: https://www.impaxx.com/cms-webinar-nghp-cmps/
Reminder: MSA Data Field Reporting
The NGHP User Guide version 8.2, released on November 18, 2025, provided new guidance to clarify how claims should be reported where a single settlement resolves multiple incidents for an individual. This update was in response to the issues experienced in reporting MSA information when that MSA is intended to cover multiple claims.
The solution outlined in the User Guide places a large burden on claim systems and unfortunately did not take into consideration how claims are managed across the industry. CMS had a webinar scheduled on October 1, 2025, to address the issue but that webinar was cancelled due to the government shutdown and has not been rescheduled as of the date of this blog.
Read more about the changes in User Guide 8.2 here: https://www.impaxx.com/nghp-user-guide-v8-2/
If you have questions about any changes made in either of these guides, or are looking for further guidance on Medicare Secondary Payer (MSP) compliance, please do not hesitate to email our experienced MSP Reporting services team at [email protected].