CMS Solicits Feedback on ORM Termination for Section 111 Reporting

The Centers for Medicare & Medicaid Services’ (CMS) Division of Medicare Secondary Payer Program Operations (DMPO) announced today that they are soliciting feedback from the external MSP community regarding the voluntary termination of Ongoing Responsibility for Medicals (ORM), as related to Section 111 reporting.

Presently, various scenarios are provided in Chapter III: Policy Guidance, Section 6.3.2 of NGHP User Guide v8.4 under which a Responsible Reporting Entity (RRE) may terminate their ORM status (when such status properly ends). DMPO is looking for feedback from RREs regarding whether the current parameters are appropriate, reasonable, and sufficient.

Any person or entity wishing to share feedback (suggestions, ideas, concerns, questions, etc.) needs to submit them to DMPO no later than Tuesday, June 9, 2026. No specific format is required, but all submissions must be e-mailed to [email protected], which is a new mailbox managed by DMPO.

While DMPO cannot guarantee a direct response to all feedback, they will take all submissions into consideration when reviewing the ORM termination policy. Comments received after June 9 will be considered for future enhancements.