By Lou Porrazzo, Esq.
Earlier today, The Centers for Medicare & Medicaid Services (CMS) announced the addition of an Open Debt Report function to the Medicare Secondary Payer Recovery Portal (MSPRP). The announcement is in line with comments that Medicare’s Steve Forry made last month at NAMSAP’s annual educational conference in Baltimore, MD.
According to CMS’s notice, on Monday October 7th, a new enhancement to the MSPRP will allow organizational debtors to create a so-called Open Debt Report. An Open Debt Report is a list of cases where Medicare is actively attempting to recover or has already sought recovery against an insurer or self-insured.
Open Debt Report can be useful for insurers and their representatives for several reasons. First, it allows organizational debtors to reconcile what they have open in their system. Second, it allows companies to uncover recovery claims that are otherwise unaware off of their radar. Finally, it gives the insurer the opportunity to alert CMS in the event that they have the wrong party identified as the debtor.
Limited Availability: Account Manager Access
There will be an Open Debt Report option only for Account Managers on their MSPRP welcome page.
Companies that have registered to use the MSPRP will be able to access the Open Debt Report at the Account Manager level only. An Account Manager will be able to run a request for an Open Debt Report, which will show all Non-Group Health Plan (NGHP) debts as of the date and time the report was generated.
We anticipate the following information on the Open Debt Report:
- Recovery Case ID
- Insurer Name
- Insurer TIN
- Recovery Agent/TPA Name (may be blank)
- RA/TPA TIN (may be blank)
- Beneficiary First Name
- Bene Last Name
- Demand Letter ID (Correspondence ID)
- Demand Letter Date (mm/dd/ccyy)
- NGHP Claim Number
- Original Demand Amount
- Current Balance and Recovery Status
Reactive Tool, but Register
Companies that have not yet registered to utilize the MSPRP may now have incentives to do so. It is important to point out that the Open Debt Report is not expected to be a panacea. While we have found prior versions of the Open Debt Report to be helpful at tracking and identifying claims, the Open Debt Report is a reactive tool. It can be used to identify problems that companies may not be aware of, but it is not a substitute for fundamental conditional payment handling practices such as adequately triaging a claim, timely filing a dispute or appeal, and using all available arguments as avenues of possible appeal.
CMS advised that additional information and instructions to create the Open Debt Report will be available in the October version of the MSPRP User Guide. ExamWorks Clinical Solutions will continue to monitor the situation and will provide updated guidance if and as required. If you need help with any aspect of Medicare conditional payments please contact our Director of Conditional Payment Services, Lou Porrazzo, Esq.
Lou oversees overall conditional payment and Treasury investigations, disputes, and appeals program. An attorney licensed to practice law in Massachusetts, Lou can be reached at firstname.lastname@example.org or 678-256-5085.