CMS Discusses– Pre-CPN Worksheet and MSPRP Open Debt Report
On January 14, 2020, the Centers for Medicare and Medicaid Services (CMS) held a town hall conference call to discuss non-group health plans (NGHP) (e.g., liability, self-insurance, no-fault, workers’ compensation, etc.) Medicare claims recovery issues related to the Commercial Repayment Center (CRC) and on-going responsibility for medicals (ORM). Nearly five years ago, the Commercial Repayment Center (CRC) assumed responsibility for the recovery of conditional payments where an insurer/workers' compensation entity is the identified debtor. CMS’s presentation can be viewed here.
Following a brief overview of the CRC recovery process, CMS announced the availability of its Pre-CPN Worksheets, comprised of a list of all open recovery claims associated with a NGHP debtor for use in identifying non-disputed debts. A non-disputed debt will trigger the CRC to send a Conditional Payment Notice for the claim within 90 days. Regarding the announcement of the Pre-CPN worksheet, we offer the following key points:
1. Only the NGHP debtor (primary payer) or its Medicare Secondary Payer Recovery Portal (MSPRP) Account Manager can request a Pre-CPN worksheet.
2. Available quarterly, Pre-CPN worksheets are purely optional, not required.
3. If requested, expect the Pre-CPN worksheets to contain a claim number and a total amount of proposed recovery debt, the worksheet is not inclusive of an itemized list of medical services and charges paid by Medicare.
4. The Pre-CPN worksheet is only for non-disputed charges and cannot be used if the NGHP debtor is disputing any compensable diagnosis, medical treatment or charges.
The town hall conference also included a discussion about the Open Debt Report and how to access it in the Medicare Secondary Payer Recovery Portal (MSPRP). The Open Debt Report was first made available through the MSPRP in October 2019 to the Medicare Secondary Payer Recovery Portal (MSPRP) Account Managers. For NGHP debtors that outsource, this report may be obtained through your agent. The Open Debt report provides a comprehensive and current list, updated each night, of a NGHP conditional payment recovery debt. The report shows the amount owed, the date the conditional payment demand was issued, and current status. Any questions regarding the accuracy of the open debt report are directed to the CRC call center at 1-855-798-2627. The CRC recovers for debt prior to the reported total payment obligation to claimant (TPOC) via MMSEA Section 111 reporting, and if ongoing responsibility for medical (ORM) Termination and TPOC is reported at the same time, the debt collection is the responsibility of the Benefits Coordination & Recovery Center (BCRC).
So, what does all this mean to your day-to-day claim’s management? First, it is critical to ensure that a monthly query file is sent to CMS, for ALL open claims. This best practice will identify all Medicare Beneficiaries for accurate quarterly MMSEA Section 111 Reporting to CMS. Next, address conditional payments early in the settlement process so that timelines for recovery are met. The CRC adheres to its 30-day dispute deadline and actively seeks delinquent debt recovery through the United States Department of Treasury for collection.
For a comprehensive Conditional Payment Checklist , visit our resources page to download our easy-to-use guide.
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