MSPRC Releases New Rights and Responsibilities (RAR) Letter
As promised, the MSPRC released the revised Rights and Responsibilities (RAR) Letter on June 10, 2011. The most significant change to the letter is that it states, in response to Haro v. Sebelius, that Medicare will not take any collection action during the pendency of an appeal or waiver request. Additionally the letter identifies a new CPN letter which will be sent when settlement information is sent to MSPRC prior to the CPL, and will provide a specific timeframe to review and/or respond before the demand is issued. While it is not entirely clear why the need for a new name, it appears that the only distinction between a CPL and a CPN is the timing with regard to settlement. Neither is a demand and action on either can be suspended with a waiver or appeal request. The MSP community continues to await the release of the revised demand letter.
The new letter format can be downloaded at: http://www.msprc.info/forms/RightsAndResponsibilitiesLetter.pdf