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.
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.
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:
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.
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.