CMS Approval in one week !?!

Medicare Set-Aside Blog on September 23, 2011
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As of July 2011, CMS began officially pilot testing the Workers’ Compensation Medicare Set-aside Portal, or WCMSAP. MEDVAL, along with 9 other vendors, was asked to participate as a trial submitter of set-aside proposals through this secure web-based system. By submitting a case through the portal, the MSA submitter no longer has to burn PDF files to a CD and mail it to Detroit. Instead, the submitter can gather the MSA proposal and its supporting documentation and upload it to this system. In doing this, the role of the COBC is eliminated. The submitter inputs the claim information, uploads the documents, and everything is sent directly to the WCRC. As stated on CMS’ own website, it is anticipated that the portal will greatly improve the efficiency of the submission process for WCMSAs, including receipt of the proposal by its Workers’ Compensation Review Contract (WCRC). The WCMSAP will allow attorneys, beneficiaries, claimants, insurance carriers, representative payees, and WCMSA vendors to:

• Create a work-in-progress case

• Submit WCMSA cases

• Perform case lookups

• Append documentation to a case

We have been participating in the pilot testing of this system since 07/22/2011. As far as the number of cases that may be submitted, this has been restricted with the number progressively increasing as the trial endures. At this point, each participant has been allotted a maximum of 18 submittals. As far as turnaround times, the results have been shocking. In contrast of what has become a standard 6-month waiting period for submissions by mail, approvals have been generated within 3-12 days, with the exception a case when CMS develops. Interestingly, even when CMS issues a development letter, you may respond via the portal, which as we saw in one case resulted in an approval within 3 days of our response. Another great feature is that the submitter can access the system and confirm the status at any point. As a final step to the process, the final, approved settlement documents can then be uploaded and completion of the case can be verified immediately.

 The question becomes CMS’ sustainability of this speed. It seems that the WCRC and CMS regional offices are strictly prioritizing these cases, even to the detriment of those previously submitted by mail and already in the system. For now, CMS holds weekly conference calls to confer with all of the trial submitters and take feedback on any issues with the system. As the majority of kinks are worked out through this trial, a fair prediction would be that the portal will continue to increase efficiency and decrease the overall review period. The unknown is what exactly happens when CMS “goes public” with this new system – sometime in mid October. Things to consider are the number of cases currently with CMS that still require review as well as the accessibility of an online system that may result in an even greater number of submissions. As one caveat, a case that does not meet CMS’ threshold for review cannot be submitted through the portal – it is immediately rejected. Although these cases can still be sent via mail, perhaps a drastic reduction in below threshold cases will reduce some of CMS’ workload. Ultimately, the system is brand new, still has a few glitches, and has been extremely limited in the number of cases it has dealt with up to this point.