In a May 26, 2026, letter to the stakeholder community, the Centers for Medicare and Medicaid Services (CMS) requested feedback on the voluntary termination of Ongoing Responsibility for Medicals (ORM), as it relates to Section 111 reporting.  Per the letter:

Currently, Chapter III, Section 6.3.2 – ORM Termination, provides various scenarios under which an RRE may terminate their ORM status when such status appropriately ends. DMPO desires industry feedback on whether the current parameters are appropriate, reasonable, and sufficient.

DMPO requests that any person or entity desiring to share feedback, ideas, concerns, or questions do so no later than June 9, 2026. Feedback need not be in any formal format or follow any particular parameters. DMPO is unable to guarantee a direct response to all feedback but will take all submissions into consideration as the policy around ORM termination is reviewed. Comments received after the above date will still be considered for future enhancements.

All submissions should be e-mailed to the new DMPO-managed mailbox relating to all Coordination of Benefits and Recovery (COB&R) inquiries:

COBR@cms.hhs.gov

ORM termination is critical not only to ending a payer’s responsibility for payment of injury-related medical care but also to allowing the injured claimant to access medical benefits for injury-related care. Even when care is not injury-related, an open ORM can still result in Medicare denying payment for medical care based on the false assumption that the treatment is related to the injury.

Tower MSA Partners will provide feedback to CMS. We encourage our client partners to share their feedback or reach out to us so we can relay your comments and concerns to CMS. Please contact Tower’s Chief Compliance Officer, Dan Anders, at daniel.anders@towermsa.com.