Starting October 11, 2025, organizations that fail to meet reporting obligations under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA 111) may face civil monetary penalties (CMPs). While this change does not alter the long-standing reporting requirements or the existing risk of liability under the federal False Claims Act for causing Medicare overpayments due to MMSEA 111 reporting errors, the introduction of CMPs significantly increases the compliance risk for insurers, self-insured entities, and third-party administrators subject to MMSEA 111.

Here is what stakeholders in the liability, no-fault, workers’ compensation, and group health plan spaces need to know.