As the No-Fault and Workers Compensation process with the Commercial Repayment Center (CRC) continues to unfold, many P&C Carriers are now receiving the next round of automated notifications from Medicare regarding outstanding conditional payments. For many, this is the first time they have seen an Intent to Refer letter.
What is an Intent to Refer (ITR) letter?
The CRC announced their process last September in a webinar just prior to their takeover of handling the Recovery for No-Fault and Workers Compensation claims. This process includes the following:
- Responsible Reporting Entities (RRE) notify the CRC of claims involving Medicare beneficiaries via Section 111 Reporting
- The CRC performs a search for any medical expenses paid conditionally by Medicare that could be related to the claim
- If charges are identified, they send a Conditional Payment Notice (CPN)
- If the CPN is not disputed within 30 days, the CRC automatically sends a Final Demand Letter (FDL)
- If the FDL is not appealed or paid within 60 days, the CRC will mail out an Intent to Refer (ITR) letter
The ITR letter is Medicare’s formal notification that recovery of one or more conditional payments is past due and that - unless the charges are appealed or paid within 60 days (the “response due date” found at the top of the letter) - they will be referred to the Department of Treasury for collection.
In other words, this is your final chance to work directly with the CRC before the matter is further complicated by the involvement of the Department of Treasury.
How should you handle your first ITR?
The most important thing to realize is that an ITR is serious. Its arrival not only means Medicare believes money is owed, but also that their records indicate at least two previous notifications regarding those monies have been sent out and not addressed within their prescribed timeframes. It’s vital that the ITR motivate immediate action on your part. If you’re already working with Flagship Services Group, forward us the ITR immediately upon receipt.
Interpreting these letters can be an added burden to insurance carriers and their claims adjusters. Most of them need to be interpreted on a case-by-case basis by someone familiar not only with claims management, but also the Medicare process and specifically the CRC’s process.
The CRC and other customer-facing Medicare departments deal with excessive documentation and correspondence every day. It’s an unfortunate hazard of the job that items can be lost, misfiled, entered incorrectly into the system, or for some other reason fail to be processed correctly.
Never assume that because you sent something to Medicare within a given timeframe that what you sent was received and properly recorded.
The need for time-consuming, diligent follow-up is another important reason Flagship customers trust their Medicare Compliance needs to us year after year. It’s simply too much work for the average claims adjuster to keep track of every separate compliance requirement on each and every Medicare claim, and the margin for error is far too large.
If you’ve already received an ITR - or if you’re concerned because you haven’t received the expected notifications from the CRC, contact Flagship Services Group today and we can discuss your options for taking this complex situation off your plate for good.