The Centers for Medicare & Medicaid Services (“CMS”) issued a Section 111 Non-Group Health Plan (“NGHP”) Alert on August 19, 2014. The Alert revises the rules pertaining to Section 111 reporting for liability insurance (including self-insurance) in cases involving exposure, ingestion, and implantation. Specifically, the Alert allows for the claims made in amended complaints or other comparable supplemental pleadings to govern Section 111 reporting obligations in the context of the December 5, 1980 cut-off.