CMS Releases Section 111 NGHP User Guide (Version 8.6)

By Mark Popolizio, J.D., Jeremy Farquhar

October 12, 2026 / 18 min read

The Centers for Medicare and Medicaid Services (CMS) has released an updated Section 111 NGHP User Guide (Version 8.6, October 5, 2026) regarding Section 111 reporting related to non-group health plans (NGHPs) (liability, no-fault and workers’ compensation).

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The authors provide an overview of the User Guide (Version 8.6) updates as follows:

Summary of Version 8.6 Updates

E-Mail address change - CMS notes that e-mails coming from COBVA@mail.cms.hhs.gov will now show the address as MSPCenter@cms.hhs.gov. As a practical matter, CMS has already been sending e-mails using the “MSPCenter” address for several months now.
New Non-Submission Notification E-mail – CMS will send this e-mail when an NGHP RRE fails to submit their Claim Input file within the last 6 months. No further details or information was provided.
Delete transaction threshold errors – CMS has modified and corrected verbiage for consistency regarding delete transaction threshold errors.
Wrongful Death Settlements - CMS has added language to existing guidance noting that these settlements are reportable “unless the RRE is able to definitively determine that all relevant documents, state law, and common law, do not permit for the recovery of medical expenses from the payment being made and that medicals were not released or had the effect of being released.”
‘NOINJ’ Diagnosis Code – CMS will no longer accept this code effective April 2027. As part of this update, CMS has updated certain applicable fields, but not others, related to this change. In addition, CMS has made updates to other data fields which raise certain issues and questions as discussed more fully below.
Qualified Settlement Funds – CMS has added new guidance outlining scenarios in which QSFs may serve as the Responsible Reporting Entity (RRE). As part of this update, CMS also notes that its QSF reporting exception does not apply to any entity paying a TPOC into the QSF which retains any right to adjudicate, review, or pay claims.
TPOC/WCMSA – CMS has introduced new guidelines for handling of scenarios where TPOC or WCMSA information had previously been reported erroneously. The guidance provided in relation to TPOC and WCMSA removal may be viewed as separate and distinct here although CMS chose to combine the guidelines together as part of their Version 8.6 updates. Both changes take effect as of April 2027. In short, starting April 2027, if TPOC info had been erroneously submitted on a coverage record where ORM is “Yes”, and the TPOC Date was on or after the ORM Termination Date, a delete transaction coupled with an add transaction will be required for correction. For WCMSA information previously submitted erroneously, which currently requires a delete/add similar to the aforementioned, it will be possible starting April 2027 to remove the erroneous MSA information via an update transaction with zeroes or spaces populated within the MSA fields according to specific field requirements.

For those interested, each of the seven (7) above updates are outlined more fully as follows:

1. E-Mail Address Change

CMS notes that “[e]mails coming from COBVA@mail.cms.hhs.gov will now show the address as MSPCenter@cms.hhs.gov.”^[1]

Comments:

Of note, CMS has actually been using the “MSP Center” e-mail address for the past several months now. As such, this update now memorializes CMS’s current practice as part of the User Guide.

2. Non-Submission Notification E-Mail

CMS notes that “[a] non-submission notification email will be sent when a NGHP RRE fails to submit their Claim Input File within the last 6 months.”^[2]

Comments:

CMS has updated Table 12-1 in Chapter II and Table 6-4 in Chapter IV to note that a non-submission notification will be “[g]enerated when a NGHP RRE fails to submit a Claim Input File within the last 6 months.”^[3] CMS has provided no further details or information regarding this update.

3. Updates Made to Delete Transaction Threshold Errors

CMS notes that “[v]erbiage has been corrected for consistency regarding delete transaction threshold errors.”^[4]

Comments:

CMS has updated existing language in the User Guide Chapter IV, Section 7.3.2 to more accurately represent when this threshold is triggered. Specifically, the old language in Section 7.3.2 stated: “There are delete transactions for more than 5% of the total records submitted.”^[5]This language has now been modified in the new User Guide (Version 8.6) to read as follows: “There are delete transactions for 5% or more of the total records submitted.”^[6]In comparing the two, CMS as part of the new update uses the phraseology of “5% or more,” as opposed to the prior language which read “more than 5%.”

4. Wrongful Death Settlements

CMS notes that “ll]anguage has been updated to clarify when it is required to submit a record for wrongful death.”^[7]

Comments:

By way of background, up through and including User Guide (Version 8.3, January 2026), CMS’s longstanding guidance contained in Chapter III, Section 6.5.1.4 stated that TPOCs obtained entirely under the wrongful death theory of liability, which did not claim and release medicals, or have the effect of releasing medicals, were not reportable because Medicare would have no recovery claim against such a payment^.[8]

Then, CMS, as part of its User Guide 8.4 updates (April 2026), removed its longstanding guidance, as stated above, and replaced it with this verbiage: “In order for the wrongful death theory of liability to preclude Medicare from recovering from a settlement, judgment, award, or other payment, complete documentation must be provided that shows what was claimed and released or had the effect of being released. Additionally, a citation to the appropriate state statute or case law that precludes recovery from a wrongful death settlement should be included with any such dispute or appeal.”^[9]

As noted in our prior article on 8.4 updates, the above verbiage, in addition to seemingly being related to Medicare conditional payment recovery versus Section 111 reporting, raised the issue of whether CMS was somehow perhaps signaling its intent to have all wrongful death settlements reported via Section 111 (which would be a significant departure from its historical guidance).

Against this backdrop, CMS has now added the following verbiage to the existing language in Section 6.5.1.4:

Wrongful Death – Many states allow for the recovery of medical expenses from the proceeds of a wrongful death settlement, judgment, or award. Further, oftentimes, a complaint alleging the wrongful death theory of liability, and the settlement documents related to an alleged wrongful death cause of action, are written in such a way that medicals are claimed and released or have the effect of being released, whether or not the parties intended that result. As such, RREs are required to report any wrongful death settlement unless the RRE is able to definitively determine that all relevant documents, state law, and common law, do not permit for the recovery of medical expenses from the payment being made and that medicals were not released or had the effect of being released.^[10]

In the big picture, CMS’s newly added verbiage can be viewed as providing additional guidance when CMS requires RREs to report wrongful death settlements. On this point, as reflected above, CMS’s new language reflects that these settlements are reportable “unless the RRE is able to definitively determine that all relevant documents, state law, and common law, do not permit for the recovery of medical expenses from the payment being made and that medicals were not released or had the effect of being released.”^[11]

5. ‘NOINJ’ diagnosis code will no longer be accepted starting April 2027

CMS notes that “[e]ffective April 2027, the NOINJ will no longer be an acceptable diagnosis code as there is no need to report a case with no injuries.”^[12]

Comments:

The ‘NOINJ’ code is a special default diagnosis code CMS established for scenarios where the type of incident in question would not typically be associated with any medical care, but where settlement/release language may still release medicals or have the effect of releasing medicals.^[13] As noted by CMS, typical examples of these scenarios include a claim for loss of consortium, an errors or omissions liability insurance claim, a directors and officers liability insurance claim, or a claim resulting from a wrongful action related to employment status action.^[14]

Historically, prior to June 2023, CMS required a TPOC report in these situations in the event of a settlement, judgment, award or other payment where settlement/release language released medicals or had the effect of releasing medicals even in scenarios where medicals were not being claimed. In these situations, CMS instructed RREs to report using ‘NOINJ’ as a default diagnosis code. However, as part of the User Guide (Version 7.2, June 2023) updates, CMS then made reporting in these situations optional.^[15]

Against this backdrop, CMS has now announced that the ‘NOINJ’ ICD code will no longer be accepted effective April 2027.^[16]The full excerpt of CMS’s updated Chapter IV language on this point is provided in the endnote to this sentence.[^17]

CMS has also applied these updates to Chapter V, Appendices A (Claim Input File Layout) and G (Disposition, Error, and Warning Flag Codes) as follows:

Appendix A: CMS has updated the Description column for the Alleged Cause of Injury (Field 15) with the statement “Effective April 2027, the following will no longer apply:” preceding the language which speaks to the potential use of the ‘NOINJ’ ICD code. However, of note, there is similar ‘NOINJ’ language within the Description field for ICD Diagnosis Code 1 (Field 18) where it appears CMS has neglected to apply this new update. From the authors’ perspective, a similar update is also necessary for Field 18 and perhaps CMS will address this with a future update.
Appendix G: CMS has added similar “Effective April 2027, the following will no longer apply:” language to the Record Layout Field Description column for the CI03 (Alleged Cause of Injury) and CI05 (ICD Diagnosis Code 1) error codes. For both of these error codes the language to which the above noted preface was added references scenarios in which the ‘NOINJ’ code may have been populated in a manner CMS would deem incorrect (either in relation to a scenario that was not ORM “No”, not connected to a liability coverage report or where additional codes other than ‘NOINJ’ had been reported in combination with an ‘NOINJ’ code) warranting rejection with one of these error codes. While those specific scenarios would, per CMS’s new guidance, no longer be applicable as of April 2027, from the authors’ perspective, if an ‘NOINJ’ code were submitted as the Alleged Cause of Injury, Incident or Illness (Field 15) or as ICD Diagnosis Code 1 (Field 18), it would seem that generation of these error codes would be appropriate simply because ‘NOINJ’ would no longer be a code accepted for purposes of Section 111 reporting, although CMS’s updates may warrant further clarification.

Finally, CMS also added an update to error code ‘CI25’ but here the update was applied to the Possible Cause column and the way the updated language now reads is arguably a bit confusing and may also warrant further clarification. Specifically, the pertinent language now reads as follows: “Field 15 was not a valid Alleged Cause of Injury, Incident, or Illness Diagnosis Code per the field requirements, or Effective April 2027, the following will no longer apply: The ‘NOINJ’ value was incorrectly submitted. When submitting the ‘NOINJ’ value, it must be submitted in Field 15 and Field 18 (ICD Diagnosis Code 1) and all other ICD Diagnosis Code fields must be blank.”

From the authors’ perspective, it is unclear exactly what the above noted language is attempting to convey in relation to the ‘NOINJ’ ICD code. Is CMS simply attempting to indicate that this error code will no longer apply to ‘NOINJ’ related scenarios? Or is CMS, instead, attempting to indicate that, if a ‘NOINJ’ code is submitted as of April of 2027, that a ‘CI25’ error will be returned without regard for whether ‘NOINJ’ specific reporting guidelines have been followed? CMS is indicating that the ‘NOINJ’ code will no longer be accepted as of April 2027, but it has not specifically indicated elsewhere what type of response will be returned on an RRE’s Claim Response File in the event that an ‘NOINJ’ code is reported as of that time. One would logically assume that CMS does intend to return an error of some sort if a ‘NOINJ’ code is submitted as the Alleged Cause of Injury, Incident, or Illness Diagnosis Code (Field 15) but which error will be returned is not clear based on CMS’s present updates. As both the aforementioned ‘CI03’ and ‘CI25’ errors are related to the Alleged Cause of Injury, Incident, or Illness Diagnosis Code, the error returned could presumably be either. Further clarification from CMS on this point would seem warranted.

6. Qualified Settlement Funds (QSF’s)

CMS notes that “[l]anguage has been updated to clarify the reporting exception for Qualified Settlement Funds (QSFs).”^[18]

Comments:

In analyzing this update, it is first noted that CMS’s statement above appears to indicate that this is an update to the agency’s longstanding reporting exception related to scenarios where funds had been paid into a Qualified Settlement Fund (QSF) prior to October 1, 2011. However, the longstanding reporting exception has remained essentially the same, with one notable caveat, and the changes here primarily focus on something quite different, although CMS chose to add these updates to the User Guide section related to the aforementioned reporting exception.

The primary changes here relate to new guidance outlining scenarios in which QSFs may serve as the Responsible Reporting Entity (RRE) for purposes of Section 111 reporting. This change represents a signature departure from CMS’s historical guidance indicating that “QSFs under Section 468B of the IRC are not RREs.”[^19]

The updates are outlined, in turn, as follows:

NEW – QSF’s as RREs

CMS has added new guidance as part of Chapter III, Section 6.5.1.8 addressing circumstances when a QSF may serve as an RRE stating as follows:

“[T]he QSF may be permitted to operate as the RRE, where permitted by law, provided that the following conditions are met:

The QSF opts to take on the role of an RRE for purposes of mandatory insurer reporting obligations; and,
There is no active ORM; and,
There are two or more entities funding the QSF; and
The QSF is operating under Section 468B of the IRC, in connection with a State or Federal bankruptcy proceeding; and,
The QSF has full, sole responsibility to resolve and pay claims utilizing funds paid into the QSF; and,
The QSF adjudicates and pays claims without review or approval of the entities that paid TPOCs into the QSF.”^[20]

QSF’s - Reporting Exception Updates

Prior to the new User Guide (Version 8.6) updates, CMS provided a reporting exception for QSF’s in situations where (a) the settlement, judgment, award or other payment is a liability insurance (including self-insurance) TPOC Amount; (b) where there is no Ongoing Responsibility for Medicals (ORM) involved; (c) the settlement, judgment, award, or other payment will be issued by a QSF under Section 468B of the IRC, in connection with a State or Federal bankruptcy proceeding; and (d) the funds at issue were paid into the trust prior to October 1, 2011.^[21]

While the above language has mostly been retained, CMS as part of User Guide (Version 8.6) updates, and in direct connection to the newly published guidance regarding circumstances in which a QSF may serve as an RRE, has indicated the following in regard to this reporting exception: “Note: Any entity paying a TPOC into the QSF, but which retains any right to adjudicate, review, or pay claims shall report as an RRE and cannot be included in the QSF reporting exception specified in this section.”^[22]

7. System Updates - Removal of TPOC/WCMSA reporting data (effective April 2027)

CMS states that “[a]s of April 2027, the system will be updated to handle the removal of TPOC and WCMSA data when the existing TPOC or WCMSA data has non-zero values and is being updated to zero values for S111 ORM Workers’ Compensation and No-Fault claims.”^[23]

Comments:

Per the above, CMS is attempting to provide new guidance regarding how RREs should handle reporting scenarios where TPOC or WCMSA information had previously been successfully reported with non-zero values, where that information has subsequently been determined to be erroneous and where removal of the previously submitted information would then be necessary.

The changes applied by CMS impact Chapter IV, Section 6.4.5 and Table 6-10 (Correcting or Removing TPOCs), Chapter IV Section 6.6.4 and Table 6-12 (Event Table), Chapter V, Appendix A (Claim Input File Layout) and Chapter V, Appendix G (Tables G-1 and G-4).

Unfortunately, in relation to these changes, while CMS has made a variety of different updates to different User Guide sections and tables within Chapters IV and V, they have not provided any overarching uniform explanation to clearly tie these numerous updates together. This may make it a bit difficult for readers to piece all of these updates into a clear and coherent understanding of CMS’s objectives and expectations. It makes analyzing these updates, as noted below, quite challenging and may very well require additional updates and clarifications from CMS.

Regarding the TPOC and WCMSA related changes, from the authors’ perspective, there appears to be disparate and, at times, seemingly contradictory information in the updated User Guide, the scope of which is beyond the scope of this article. Very generally, CMS has retained longstanding historical guidance in certain areas regarding updating or removing previously submitted TPOC information which may now be out of sync with some of CMS’s newly published updates.

Notwithstanding, taking CMS’s newly added language on its own, without regard for any conflicts with other longstanding historical guidance still present throughout the User Guide, the summary provided below is the authors’ best interpretation of the forthcoming changes scheduled for April 2027, based on the existing information provided by CMS, and recognizing that additional guidance and clarity from CMS in certain areas would be helpful:

Removing previously submitted erroneous WCMSA information: Currently, as part of TPOC/WCMSA reporting, to successfully and entirely remove WCMSA information that was previously submitted entirely erroneously, submission of a delete transaction is required. However, based on the author’s interpretation of CMS’s updates, beginning in April 2027, removal of erroneously submitted MSA information should be possible by simply submitting an update transaction with all associated WCMSA related fields populated with either zeroes or spaces, as applicable, based on the default value for the associated field.[^24]
Removing previously submitted erroneous TPOC information where ORM is “Yes” and at least one TPOC is on or after ORM Termination: Historically, if an RRE needed to remove erroneously submitted TPOC information in this scenario, RREs have been simply instructed to submit zeroes within the same TPOC Date and TPOC Amount fields via which the erroneous information had previously been submitted. These are the same instructions historically provided in relation to removal of erroneous TPOC information in all scenarios, except situations where the only TPOC(s) reported was/were erroneous and ORM was “No”, in which case a delete would be required. However, based on the authors’ interpretation of CMS’s updates, beginning April 2027, in any scenario where ORM is “Yes” and an RRE is attempting to remove all previously reported TPOC information, where at least one previously reported TPOC Date is on or after the ORM Termination Date, RREs will be required to submit a delete transaction coupled with an add transaction. The delete record should be submitted with all data elements populated with the same information previously reported. The add record should then be submitted with all previously submitted TPOC fields populated with zeroes and all other data elements populated with the same values previously submitted.^[25]

Also being implemented in April 2027, in association with this change, is a new ‘04’ Disposition Code value. In scenarios such as those outlined above, where ORM is “Yes”, if an RRE attempts to update all previously submitted TPOC data elements with zero values, where at least one TPOC was on or after the ORM Termination Date, CMS will return this new ‘04’ disposition code in order to indicate that the “submitted TPOC information was not processed and requires review.”^[26]In this scenario, the RRE should resubmit delete and add transactions as outlined above per CMS’s new requirements. Additionally, if an attempt is made to zero out one or more previously submitted TPOC data elements in a scenario where a demand has already been issued for an associated conditional payment recovery case, this new ‘04’ disposition code will also be returned. In this scenario, CMS indicates it would expect a request for redetermination to be submitted via the conditional payment recovery process by the debtor or their representative.^[27]

Finally, within its Summary of Version 8.6 Updates, referenced at the beginning of this segment, the reader will note that CMS’s description of the changes also references “no-fault” claims, although CMS’s actual updates make no further specific reference to no-fault claims.^[28]At face value this would seem incongruent as there would be no connection to MSA reporting in relation to no-fault coverage and no-fault specific TPOC scenarios tend to be quite rare. However, the authors assume here that no-fault coverage was referenced within CMS’s summary in possible connection to the new TPOC reporting guidance outlined above, as this guidance is specific to ORM “Yes” scenarios, and could apply in the unlikely event of a no-fault TPOC.

Going forward, we will need to see if CMS eventually releases any additional information or clarity on these points.

Questions?

Please do not hesitate to contact the authors if you have any questions regarding the above, or how Verisk can help you with your Section 111 reporting obligations.

[1] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters I, II and IV, Chapter 1: Summary of Version 8.6 Updates.

[2] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters II and IV, Chapter 1: Summary of Version 8.6 Updates.

[3] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters II, Table 12-1 and Chapter IV Table 6-4.

[4] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters IV, Chapter 1: Summary of Version 8.6 Updates.

[5] CMS’s Section 111 NGHP User Guide (Version 8.5 July 2026), Chapter IV, Section 7.3.2.

[6] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), ChaptersIV, Section 7.3.2.

[7] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapter II, Chapter 1: Summary of Version 8.6 Updates.

[8] See e.g., “Settlements, judgments, awards, or other payments obtained entirely under the wrongful death theory of liability, which do not claim and release medicals, or have the effect of releasing medicals, are not required to be reported because Medicare would have no recovery claim against such a payment.” CMS’s Section 111 NGHP User Guide (Version 8.3, January 5, 2026), Chapter III, Section 6.5.1.4. In addition, on the point, it is further noted CMS noted this guidance during the Q&A Segment of its September 12, 2024, NGHP Reporting Best Practices webinar, in the feedback it gave in response to a question it received regarding “What is the best way to report a strictly wrongful death case to Medicare under S111?” In response, CMS stated that if medicals were not claimed and released, then there is no need to report the settlement since Medicare would have no right to recover where medical expenses were not contemplated, included, settled, or otherwise released. On the other hand, if medicals were claimed and released, then reporting is necessary, even if the claim was entirely for wrongful death and was appropriately allocated. CMS’s Non-Group Health Plan (NGHP) Section 111 Reporting Webinar (September 12, 2024), Questions and Answers page 3.

[9] CMS’s Section 111 NGHP User Guide (Version 8.4, April 13, 2026), Section 6.5.1.4.

[10] CMS’s Section 111 NGHP User Guide (Version 8.4, April 13, 2026), Section 6.5.1.4.

[11] CMS’s Section 111 NGHP User Guide (Version 8.4, April 13, 2026), Section 6.5.1.4.

[12] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapters IV and V, Section 1: Summary of Version 8.6 Updates.

[13] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Section 6.2.5.2.

[14] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Section 6.2.5.2.

[15] CMS’s Section 111 NGHP User Guide (Version 7.2, June 5, 2026), Chapter IV, Section 6.2.5.2.

[16] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Section 6.2.5.2.

[17] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Section 6.2.5.2 now reads as follows:

6.2.5.2 Settlements That Should Not Be Reported – NOINJ Code

As documented in the NGHP User Guide Policy Guidance Chapter III (Section 6.5.1 - What Claims Are Reportable/When Are Such Claims Reportable) and elsewhere in this guide: Information is to be reported for claims related to liability insurance (including self-insurance), no-fault insurance, and workers’ compensation where the injured party is (or was) a Medicare beneficiary and medicals are claimed and/or released or the settlement, judgment, award, or other payment has the effect of releasing medicals.

There are certain, very limited, liability situations where a settlement, judgment, award, or other payment (TPOC) releases medicals or has the effect of releasing medicals, but the type of alleged incident typically has no associated medical care and the Medicare beneficiary or injured party has not alleged a situation involving medical care or a physical or mental injury. This is frequently the situation with a claim for loss of consortium, an errors or omissions liability insurance claim, a directors and officers liability insurance claim, or a claim resulting from a wrongful action related to employment status action. In these situations, there is no need to report such a settlement, as there are no associated Medicare-covered items or services because there is no injury being alleged which would lead to Medicare-covered items or services. RREs should continue to utilize all appropriate due diligence in attempting to identify any injuries and applicable ICD codes related to the incident in question. An inability to identify the exact ICD codes is not an appropriate reason to not report the TPOC if an injury or illness was claimed and released. Use of the “NOINJ” diagnosis code will no longer be accepted and system logic has been implemented to prevent submission of the “NOINJ” code.”

[18] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter III, Section 1: Summary of Version 8.6 Updates.

[19] CMS’s Section 111 NGHP User Guide (Version 8.5, June 13, 2026), Chapter III, Section 6.5.1.8.

[20] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter III, Section 6.5.1.8.

[21] CMS’s Section 111 NGHP User Guide (Version 8.5, June 13, 2026), Chapter III, Section 6.5.1.8.

[22] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter III, Section 6.5.1.8.

[23] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters IV and V, Chapter 1: Summary of Version 8.6 Updates.

[24] See CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Sections 6.4.5 and 6.6.4 as well as CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter V, Appendix A.

[25] See CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter IV, Section 6.6.4 as well as CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter V, Appendices A and G.

[26] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter V, Appendix G. The full text of the ‘04’ Disposition Code reads as follows: “Claim Response File: Submitted TPOC information was not processed and requires review. For claims with ongoing responsibility for medicals (ORM), attempting to update all non-zero TPOC data to zeroes is not accepted when at least one affected TPOC date is on or after the ORM Term Date. If attempting to delete all previously reported TPOC data, submit a delete record and a new add ORM claim record with the original values but without the TPOC data.

For any claim, attempting to update one or more non-zero TPOC data to zeroes is not accepted when the related recovery case has been demanded. A request for redetermination must be submitted by the debtor or their representative.”

[27] CMS’s Section 111 NGHP User Guide (Version 8.6, October 5, 2026), Chapter V, Appendix G.

[28] CMS’s Section 111 NGHP User Guide (Version 8.6, October 2026), Chapters IV and V, Chapter 1: Summary of Version 8.6 Updates.