CMS presented a second webinar on September 17, 2015 about the transition of the Non-Group Health Plan (NGHP) recovery process to the Commercial Repayment Center (CRC).. The majority of the material addressed was identical to that presented in the August 25, 2015 webinar, which is summarized in our earlier blog.
Key points raised during the webinars include the following:
-The October 5, 2015 transition to the CRC will only impact new conditional payment recovery actions directed towards a liability insurer (including self-insurance), no-fault insurer, or a workers’ compensation entity, or otherwise known as Applicable Plans.
-Recovery will be directed toward an Applicable Plan when it reports “Ongoing Responsibility for Medical” or otherwise notifies CMS of its undisputed primary payer responsibility. In this situation, a Conditional Payment Notice (CPN) will be issued to the Applicable Plan.
-Payments identified in a CPN may be disputed once within 30 days of the date of the CPN. Failure to dispute the CPN will result in the issuance of a demand letter or initial determination. Administrative appeal rights are available once the initial determination is issued.
-A Conditional Payment Letter (CPL) is issued when a beneficiary or his representative self-report a claim and the MSP occurrence was not otherwise reported by the Applicable Plan. Conditional payments noted in a CPL may be disputed at any time.
-The CPL, CPN and demand letters to the Applicable Plan will contain a Statement of Reimbursement, which will list the amounts of the conditional payments, the service dates and the diagnostic information pertaining to the payments.
-The CRC may recover conditional payments made after the primary payment responsibility has ended if the payments were made while the primary responsibility was in effect.
-Applicable Plans may access and dispute recovery case information when CMS is pursuing recovery against the Plans as the identified debtors through the Medicare Secondary Payer Recovery Portal (MSPRP).
-CRC will send all recovery correspondence to the address identified for the Applicable Plan in its MMSEA Section 111 reporting profile.
-Recovery agents identified through the Section 111 Mandatory Insurer Reporting profile will be included on all CRC correspondence up to and including the demand letter.
– The CRC must have a written authorization in each of its files if the Applicable Plan wants another entity, such as the recovery agent, to participate in the post demand conditional payment recovery process.
-The Benefits Coordination and Recovery Center (BCRC) will continue to handle recovery actions initiated prior to October 5, 2015 and all claims where the identified debtor is the beneficiary.
We will keep you advised of further developments as they arise.