The Centers for Medicare and Medicaid Services (CMS) released an updated version of the Medicare Secondary Payer Recovery Portal (MSPRP) User Guide (Version 3.5) which documents improved functionality and access on the MSPRP including portal use for matters pending with the Commercial Repayment Center (CRC). Given the delays in obtaining documentation from the CRC, the expansion of the portal to cover claims with the CRC is an improvement in CMS’s Medicare conditional payment processes.
Below is a breakdown of the specific announced changes to the MSPRP with an explanation as to why these changes are important to the resolution of Medicare conditional payments. Details follow regarding the CMS Town Hall Teleconference on the MSPRP upgrades and the CRC.
MSPRP Implemented Changes
- To help distinguish between a recovery agent submitted on a Responsible Reporting Entity’s (RRE’s) Section 111 (S111) TIN Reference File and a recovery agent that submitted recovery agent authorization, which have slightly different authority levels, Recovery Agents who are associated to an insurer-debtor case as the insurer’s S111 Recovery Agent may now submit a Recovery Agent authorization. An S111 Recovery Agent has authorization on an insurer debtor case pre-demand. An entity with an active Recovery Agent Authorization in verified status has authority on an insurer-debtor case both pre- and post-demand (Section 10.3.3).
Why this is important: A Recovery Agent submitted in an RRE TIN Reference File only has authority to act on behalf of the RRE when it comes to pre-demand Medicare conditional payment matters. Once the demand is issued, such Recovery Agent must also submit a Recovery Agent authorization executed by a representative of the RRE to file an appeal of the demand on behalf of the RRE. This change allows the Recovery Agent to submit such authorization and thus file the appeal.
- To allow authorized users to edit settlement information prior to initiating a demand and allow them to view settlement information after submission, authorized users can now:
• Add or update settlement information after clicking the Initiate Demand Letter action on the Case Information page. (13.1.10).
• View read-only settlement information after it’s been provided (Section 13.1.9). Additionally, the Provide the Notice of Settlement Information action on the Case Information page has been renamed to View/Provide the Notice of Settlement Information.
Why this is important: Instances occur where incorrect settlement information is provided through the portal. This function allows for a change to be made even after initiating a request for a Demand Letter.
- To ensure consistency, the case statuses displayed for Commercial Repayment Center (CRC) cases have been revised to better match the case statuses displayed for Benefits Coordination & Recovery Center (BCRC) cases (Table 13-2).
Why this is important: The explanation is self-explanatory, to ensure consistency.
- To provide similar BCRC functionality for CRC cases:
• Users may now request an update to the conditional payment amount (Section 13.1.2).
• Beneficiaries and beneficiary representatives with verified Proof of Representation (POR) who log in using multi-factor authentication may now request an electronic Conditional Payment Letter (eCPL), or a mailed copy of the Conditional Payment Letter (CPL). Additionally, if requested, these users will also receive an electronic or mailed version of the “no claims paid by Medicare” letter where the overpayment amount = $0 (Section 13.1.3).
• Authorized users may now submit unlimited disputes any time prior to the case being demanded, after a conditional payment notice (CPN) or a CPL has been issued (Section 13.1.5).
Why this is important: This functionality had previously only been available with the BCRC on matters where the claimant is the identified debtor. These functions are now available with the CRC on matters where the RRE (employer/carrier) is the identified debtor.
- To let users know that the final conditional payment (CP) amount displayed on the WARNING - Calculate Final Conditional Payment Amount Can Only Be Selected Once page may be different than the final amount shown on the Confirmation page, the text shown on the Warning page has been modified to indicate that the final CP amount may decrease if unrelated claims are identified and removed from the conditional payment amount (Figure 14-4).
Why this is important: This advises the entity requesting a Pre-Settlement Final Conditional Payment amount that the identified debtor does not lose its post-demand appeal rights because they are obtaining a pre-settlement Final Conditional Payment Amount.
Examworks Clinical Solutions applauds the actions by CMS to continuously seek methods to improve the conditional payment process for all stakeholders. As the global leader in MSP Compliance and Section 111 reporting for NGHP entities, ECS is committed to assuring your MSP compliance and awareness of any changes.
The updated User Guide may be found here.