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Commercial Repayment Center (CRC)

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:

  • MedPay
  • PIP
  • 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.

  • Are You My Mother? (12/3/2019) - In Dr. Seuss’ classic book, a determined baby bird is searching for his mother but does not know what she looks like. Under Medicare Secondary Payer (MSP), certain insurers encounter similar problems trying to figure out whether it is a Primary Plan with Section 111 and reimbursement obligations.
  • Into the Looking Glass (11/20/2019) - Business organizations face all kinds of risk. Developing strategic risk management plans as a business practice is becoming more prevalent across industry lines which help the organization define, measure, anticipate, and respond, for example, to foreseeable risks, technological developments, as well as changing laws and regulations. Some risk is insurable, while other kinds may necessitate capital, cost or other investment such as an organization adding new personnel or contracting with subject matter specialists or consultants. Some risk is not as perceptible as others, yet still must be handled if it occurs. Ideally, an effective risk management plan is tailored to the organization and ultimately improves its performance by avoiding, minimizing or mitigating risk.
  • Ghostbusters (11/1/2019) - In 1984, Ivy League trained parapsychologists Venkman, Stantz, and Spengler started a ghost-catching business in New York City, despite implausible research, and eventually were welcomed as heroes by saving the city from the paranormal disguised as giant marshmallow man Stay Puft. Only in the movies! But, we can use this ghoulish time of the year to serve as a reminder: Don’t let MSP enforcement claims by Medicare Part C Advantage Plans sneak up to shock and detract your standard claims operating procedures. Identifying and resolving these repayment claims may be just as important a part to your overall MSP compliance strategy as similar claims by traditional Medicare Parts A and B.
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