Medicare Commercial Repayment Center
The Commercial Repayment Center (CRC) will now pursue recovery on claims where the insurer is the debtor: typically No-Fault and Workers’ Compensation claims. This change can leave P&C Insurers scrambling to keep up, but Flagship Services Group is here to help you overcome pending challenges.
Immediate Effects of Reporting via Section 111
Insurers can expect the CRC to review claims reported via Section 111 reporting to determine if conditional payments were made by Medicare that need to be recovered. However, unlike their counterparts at the BCRC, they will not wait for the settlement to be finalized before pursuing reimbursement. As soon as an insurer reports the assumption of ORM, the CRC will investigate whether Medicare has already made payments they believe are related to the claim and send Conditional Payment Notices (CPN). The CRC begins recovery work immediately without waiting for termination of Ongoing Responsibility for Medicals (ORM) or settlement. Accurate Section 111 reporting will be crucial.
Increased Conditional Payment Notices
Based on its audits of reported claims, the CRC will issue a Conditional Payment Notice on every workers’ comp or no-fault claim reported under Section 111 when they have determined Medicare has paid bills related to that claim. The CRC’s focus includes:
- Workers’ Compensation
- Currently, it does not include TPOCs
The Conditional Payment Notice outlines all charges Medicare has paid and expects to be reimbursed. In other words, Medicare will send a bill for every single claim where they should be the secondary payer. You can never assume that all the charges on a CPN are related to the injuries sustained.
Automatic Demand Letters
If a Responsible Reporting Entity (RRE) feels the charges are unrelated, you have only 30 days to dispute the charges. If no dispute is submitted in the 30 day timeframe, the CPN automatically converts to a Final Demand letter (FDL) and interest will start to accrue. This requires RREs to dispute the CPN within a month. If you do not respond within the 30 days, you will possess a FDL.
How Does Flagship Help?
- Flagship has been reviewing and disputing CPNs for several years. We have a proven process to work with Medicare.
- Flagship’s proprietary LumenX claims system ensures that every Medicare-related claim is properly identified, reported, and reviewed for recovery.
- Compliance experts review every Medicare claim to make sure you’re reporting and reimbursing Medicare for everything they are rightfully owed, but not a penny more.
- Our free risk analysis can quickly identify gaps in your compliance process and prevent unnecessary fees.
- Top 10 MSP Compliance Waypoints in 2019 (8/12/2019) - Key moments, thus far, to review and consider on the 2019 Medicare Secondary Payer voyage. Medicare Secondary Payer compliance can be complex with many changes to track from different and connected sources which affect administrative policies, procedures and processes. Flagship’s educational solutions are thoughtfully designed to explain matters in simple terms which help your team […]
- Flagship Welcomes Robert J. Finley as Chief Legal Consultant (8/2/2019) - August 5, 2019 Valued Flagship Clients, Flagship Services Group, is pleased to announce that Robert J. Finley will serve as our Chief Legal Consultant. We are excited to work with Mr. Finley, who brings both knowledge and practical experience in Medicare Secondary Payer (MSP) compliance and regulation, as well as Medicaid third party liability and […]
- Progressive Insurance Company Settles Medicare and Medicaid Secondary Payer False Claims Act for $2.4 Million (11/22/2018) - Auto, liability, no-fault, and work comp primary payers- if you didn’t take Medicare and Medicaid secondary payer issues seriously before, here are over 2 million reasons why you should. On November 14, 2017, the United States of America, the State of New Jersey, Progressive Garden State Insurance Company, Progressive Casualty Insurance Company, and Relator Elizabeth […]