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.
- Good Things Take Time, as They Should (2/28/2020) - Legendary college basketball coach John Wooden led UCLA to 10 men’s national championships in 12 years, from 1964 to 1975. But, becoming a champion did not happen overnight. Coach Wooden’s coaching career started in 1946 at Indiana State, and then he spent 15 winning seasons at UCLA before he coached a championship team. His path to the top, and staying there, was not easy, quick or cheap.
- Civil Money Penalties (2/17/2020) - The Centers for Medicare and Medicaid Services (CMS) is set to release their proposed rulemaking for Civil Money Penalties (CMP’s) regarding Medicare reporting. CMS is expected to publish the proposed rule on Tuesday, February 18, 2020 and is accepting public comment for 60 days. The deadline to submit comments will be Monday, April 20, 2020. […]
- Robert J. Finley to Present at 5th Annual RISE Medicare Secondary Payer Master Class (1/29/2020) - Robert J. Finley, Partner with Hinshaw & Culbertson LLP and Chief Legal Consultant to Flagship Services Group, will provide a series of presentations at the 5th Annual RISE Medicare Secondary Payer Master Class, to be held February 3 – 4, 2020 in Jacksonville, Florida. The comprehensive two-day event is designed for mid to senior level management and legal professionals who are responsible for Medicare Secondary Payer compliance in risk management, finance, enforcement, and legal roles.