The Medicare, Medicaid and SCHIP Extension Act of 2007 ("MMSEA" Section 111) poses a complex, administrative quagmire for insurers, self-insured entities, and their counsel.  A dangerous combination of convoluted reporting requirements and hopelessly vague methods of implementation have led the Centers for Medicare & Medicaid Services ("CMS"), the very agency charged with implementing the provisions of the Act, to postpone reporting requirements until January 1, 2011.  However, in the mass tort arena, even the temporary postponement of the reporting requirements raises issues which should be addressed in the coming year by the cautious party.  Under the recently revised guidelines, CMS has amended the obligation to report claims on which the Total Payment Obligations on Claims ("TPOC") accrues as of October 1, 2010, and to report claims in which ongoing responsibility for medicals (ORM) exists as of January 1, 2010.  Given the draconian penalties for failure to comply with the Act, a close watch will need to be kept by all potentially affected parties over the upcoming year.