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Section 111 Mandatory Reporting Application (MRA)

How to Get Started

Responsible reporting entities (RREs) must notify the Benefits Coordination & Recovery Center (BCRC) of their intent to report data to comply with the requirements of Section 111 of the MMSEA. Each RRE is required to register before testing between the RRE (or its agent) and the BCRC can begin. Through the registration process, the BCRC will obtain the information needed to:

  • Validate information provided by the RRE registrant,
  • Assign Section 111 Reporter IDs (RRE IDs) to each RRE,
  • Develop a Section 111 reporting profile for each entity, including estimates of the volume and type of data to be exchanged for planning purposes,
  • Assign a production live date and ongoing file submission timeframe to each entity,
  • Establish the necessary file transfer mechanisms,
  • Assign a BCRC Electronic Data Interchange Representative (EDI Rep) to each entity to assist with ongoing communication and data exchange, and
  • Assign login IDs to individual users associated with each RRE account.

Section 111 registration and account setup is a five-step process, as described next.

Step 1: Identify an AR, Account Manager, and other COBSW Users

Each RRE must assign or name an Authorized Representative (AR). This is the individual in the RRE's organization who has the legal authority to bind the organization to a contract and the terms of MMSEA Section 111 requirements and processing. The AR has ultimate accountability for the RRE's compliance with Section 111 reporting requirements. Please refer to the Data Use Agreement in the Section 111 user guide to make sure the person you name as your AR has the authority to sign this agreement.

The AR:

  • Cannot be a user of the Section 111 COBSW for any RRE ID.
  • Cannot be an agent of the RRE.
  • May perform the initial registration on the COBSW or delegate this task to another individual, but will not be provided with a login ID.
  • Will designate the Account Manager (AM).
  • Must approve the account setup, by physically signing the profile report, including the Data Use Agreement, and returning it to the BCRC.
  • Will receive BCRC notifications related to non-compliance with Section 111 reporting requirements.

Each RRE must assign or name an AM. Each RRE ID can have only one AM. This is the individual who controls the administration of an RRE's account and manages the overall reporting process. The AM may choose to manage the entire account and data file exchange, or may invite other company employees or data processing agents to assist (Account Designees, or ADs).

To register as an AR, go to the application home page (https://www.cob.cms.hhs.gov/Section111/), accept the user agreement, then click on Step 1: New Registration. In the registration process, you will enter RRE and corporate structure information as well as AR information.

The AM:

  • Must register on the COBSW, obtain a login ID, and set up the account.
  • Can be an AM associated with another RRE ID if they receive the authorized PIN from the BCRC. This would occur when a reporting entity has multiple RRE IDs under which they will report separate Input Files or when the entity chooses to name an agent or third-party administrator (TPA) as its AM.
  • Can invite other users to register on the COBSW as ADs.
  • Can manage the RRE's profile including selection of a file transfer method.
  • Can upload and download files to the COBSW if the RRE has specified HTTPS as the file transfer method.
  • Can use their login ID and password to transmit files if the RRE has specified SFTP as the file transfer method.
  • Can review file transmission history.
  • Can review file-processing status and file statistics.
  • Can remove an AD's association to an RRE ID account.
  • Can change account contact information (e.g. address, phone, etc.).
  • Can change their personal information.
  • Cannot be an AR for any RRE ID or an AD for the same RRE ID.

To register as an AM, Step 1 - New Registration must be completed by the AR. After the initial registration step is completed, the RRE ID associated with the account will be shown on the registration confirmation Thank You page. Once the registration information is validated, the BCRC will then send an email to the named AR with a personal identification number (PIN) associated with the registration.

The AR must give this PIN and RRE ID to their AM. The AM can then go to the COBSW and click Step 2: Account Setup. During account setup, the AM will create a login ID and password.

At the RRE's discretion, the AM may designate other individuals to register as ADs: users of the COBSW associated with the RRE's account. ADs assist the AM with the reporting process. ADs may be RRE employees or agents. There may be up to 200 ADs associated with one RRE ID.

The AD:

  • Must be invited by an AM, register on the COBSW, and obtain a login ID.
  • Can be associated with multiple RRE accounts, but only by an AM invitation for each RRE ID.
  • Can upload and download files to the COBSW if the RRE has specified HTTPS as the file transfer method.
  • Can use their login ID and password to transmit files if the RRE has specified SFTP as the file transfer method.
  • Can review file transmission history.
  • Can review file-processing statuses and file statistics.
  • Can change their personal information.
  • Cannot be an AR for any RRE ID or an AM for the same RRE ID.
  • Cannot invite other users to the account.
  • Cannot update RRE account information.

Agents:

RREs may use agents to submit data on their behalf. An agent is a data services company, consulting company, or the like that can create and submit Section 111 files to the BCRC on behalf of the RRE. Information on the use of agents is required as part of the Section 111 registration process.

To supply agent company information, Step 1 - New Registration must be completed. If you have gone through the initial registration process, have your RRE ID, and have received your email containing your PIN from the BCRC, your AM can click on Step 2: Account Setup. Agent information is collected as part of this process. An individual associated with an RRE’s agent can be the AM or an AD associated with the RRE ID.

Note: Each user of the Section 111 application on the COBSW will have only one login ID and password. With that login ID and password, you may be associated with multiple RRE IDs (RRE accounts). With one login ID, you may be an AM for one RRE ID and an AD for another. In other words, the role you play on the COBSW is by RRE ID.

Step 2: Determine Reporting Structure

Before beginning the registration process, an RRE must also determine how the RRE will submit Section 111 files to the BCRC and how many Section 111 Reporter IDs (RRE IDs) will be needed. Only one GHP MSP Input File may be submitted on a quarterly basis for each GHP RRE ID. Liability insurance/no-fault insurance/workers' compensation RREs may only submit one Claim Input File for each RRE ID per quarter. Due to corporate organization, data processing system structures, and agents that may be used for file submission, you may want to submit more than one Input File to the BCRC on a quarterly basis and therefore need more than one RRE ID in order to do so.

For example, if an RRE will use one agent to submit one set of GHP coverage information and another agent to submit another set of GHP coverage information, the RRE must register on the COBSW twice to obtain two RRE IDs that will be used by each agent respectively. You may name the same AR and AM for both accounts, or use different individuals. Likewise, if you have two or more subsidiary companies that handle different regions of the country (or different lines of business) using different data processing systems, and you will not combine the quarterly Input Files for Section 111 reporting, you must register for each quarterly file submission to obtain separate RRE IDs in order to submit multiple Input Files in one quarter. Alternatively, if you will submit only one Claim or MSP Input File per quarter, you will need only one RRE ID. Using the same RRE ID, one agent could submit your Claim or MSP Input Files and another agent could submit your Query Files. Please see the Section 111 user guide for more information.

You may not set up a separate RRE ID for submission of the Query File or GHP Non-MSP Input File only. You must submit a quarterly GHP MSP Input File or liability/no-fault/workers' compensation Claim Input File for every RRE ID you establish.

If an RRE has both GHP and liability/no-fault/workers' compensation data to report for Section 111, it must establish separate RRE IDs. Data for GHP and liability/no-fault/workers' compensation must be submitted separately under separate RRE IDs.

Step 3: New RRE ID Registration on the COBSW

A company representative for the RRE must go to the Section 111 COBSW URL (https://www.cob.cms.hhs.gov/Section111/), click on the New Registration button, complete and submit the registration for the RRE. This step must be completed by the RRE, not an agent for the RRE. It is critical that you provide the AR information (including email address) in this New Registration step and not the email address for someone you want to be a user of the COBSW.

The application will ask that you submit:

  • A Federal Tax Identification Number (TIN) for the RRE
  • Company name and address
  • Company authorized representative contact information (name, job title, address, email address, phone)
  • National Association of Insurance Commissioners (NAIC) company code, if applicable
  • Reporter Type (GHP or liability/no-fault/worker's compensation)
  • Optional Subsidiary company information to be included in the file submission for the registration (names, TINs, NAIC company codes for the subsidiaries)

After the initial registration step is completed by the representative, the RRE ID is shown on the registration confirmation Thank You page. When a registration application is submitted, the information provided will be validated by the BCRC. Once this is completed, the BCRC will send an email to the named AR with a personal identification number (PIN) associated with the registration.

The AR must give this PIN and the RRE ID to their AM to use to complete the account setup step.

If you need more than one RRE ID for Section 111 reporting, this step must be repeated for each.

Step 4: RRE Account Setup on the COBSW - AM

In order to set up the RRE account, the RRE's AM must go to the Section 111 COBSW URL (https://www.cob.cms.hhs.gov/Section111/) with the PIN and RRE ID and click on the Account Setup button. Only the individual who will be the AM for the RRE ID may set up the account.

The AM will:

  • Enter the RRE ID and associated PIN.
  • Enter personal information including name, job title, address, phone, and email address.
  • Create a login ID for the COBSW.
  • Enter account information related to expected volume of data to be exchanged under this RRE ID (estimated number of covered individuals and estimated number of covered individuals age 45 and over).
  • Enter reporting agent name, address, contact email and TIN.You must obtain this information from your agent, including the agent's TIN, before you can set up the account.
  • Select a file transmission method.

This step must be repeated for each RRE ID.

Once the AM has successfully obtained a COBSW login ID, the AM may log into the application and invite ADs to register for login IDs. Also, after completing account setup for first RRE ID, since only one login ID is required per user, the system will bypass the steps for creating another login ID and password during account setup for subsequent RRE IDs.

NOTE: If you have been invited to be an AD for an RRE ID previously, you must complete the AD registration process and obtain a login ID before you may set up an account for another RRE ID as the AM. In other words, if you have an AD invitation pending, you must complete the AD registration process and obtain a login ID before you may proceed with setting yourself up as an AM for other RRE IDs. We strongly encourage users to register as soon as possible after receiving an invitation email to avoid problems completing account setup for other RRE IDs.

Step 5: Return Signed RRE Profile Report - AR

Once account setup has been completed on the COBSW and processed by the BCRC, a profile report will be sent to the RRE's authorized representative via email.

The profile report contains:

  • A summary of the information you provided on your registration and account setup
  • Important information you will need for your data file transmission
  • Your RRE ID that you will need to include on all files transmitted to the BCRC
  • Your assigned production live date and ongoing quarterly file submission timeframe for the MSP or Claim Input File
  • Contact information for your EDI Representative who will support you through testing, implementation, and subsequent production reporting.

The RRE's AR must review, sign, and return the profile report to the BCRC. Once your profile report has been marked as received by the BCRC, you may begin testing your Section 111 files. The BCRC will send an email to your AR and AM indicating that testing can begin.