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The Medicare Secondary Payer (MSP) program has long suffered from inadequate mechanisms to identify settlements and payments that may be subject to recovery efforts. Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA)1 dramatically changes the status quo effective January 1, 2011 by forcing third-party payors to self-disclose settlements, payments, and other awards with or to Medicare beneficiaries. Healthcare providers, like other entities that may settle or pay reportable claims, are subject to Section 111's mandatory reporting requirements and the $1000 per-day penalty for non-compliance. (Reporting is not limited to insurers.) This article briefly summarizes reporting obligations applicable to healthcare providers and identifies ancillary issues that healthcare providers should address in developing a Section 111 program.

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