MSPRP E-Payments Go Live On April 1, 2019
Yesterday, the Centers for Medicare and Medicaid Services (CMS) held a high level overview webinar of changes coming to the Medicare Secondary Payer Recovery Portal (MSPRP), as we recently discussed here on our blog. The webinar addressed the most recent upcoming enhancement, which will allow electronic payments to be submitted directly through the MSPRP.
As it stands currently, MSPRP users utilize the portal only to manage recovery cases, but mail checks for payments of conditional payments directly to the Benefits Coordination & Recovery Center (BCRC) or the Commercial Repayment Center (CRC). However, as of Monday, April 1, payments for demands for Non-Group Health Plans (liability insurers (including self-insurers), no-fault insurers, and workers’ compensation entities) will be able to submit payment via the MSPRP and to confirm that the payment has been accurately applied. Users who choose to utilize this latest MSPRP enhancement will be redirected from the MSPRP to Pay.gov. Pay.gov is a secure web-based online payment system that is run by the Department of the Treasury and allows for online payments to be made to government agencies by electronic check, credit card, debit card or pay pal (if linked to a bank account). There is no additional fee to use Pay.gov. However, debit cards will be declined if the maximum amount of $24,999.99 is exceeded using this new payment feature, and payment using a PayPal account cannot exceed $10,000. Once a payment has been processed, a confirmation will be received. The MSPRP will further allow users to view information about all electronic payments on a new “Electronic Payment History” tab, including an updated demand status with the corresponding date. Payment processing times will average from 1-3 business days; however, CMS will accept the date the electronic payment was made as the payment received date rather than the date the payment is actually processed. This is of significant note, as we have seen some inconsistencies when checks have been sent for payment of a demand. Specifically, we have seen the CRC utilize the date the check has been received rather than the date of the check and physical mailing date of the payment.
Of note, partial payments for demands can be made using this new feature, however, interest will continue to accrue on any unpaid demand amount. CMS also indicated that conditional payment redeterminations, waivers, or compromise requests will still be considered, and will not be impacted by this new feature, as refunds can still be processed despite an electronic payment being made. Refunds made on any electronic payment will be made in the form of a paper check and will be processed under current protocols and turnaround times.
Takeaway and Commentary:
The new payment feature will certainly prove to be a useful tool for those who utilize the MSPRP, as well as beneficiaries, who may also access the MSPRP through MyMedicare.Gov. For quite some time, MSP industry stakeholders have requested a more efficient process by which to make payments and track any payments made for conditional payments identified by the CRC. It is important to note once again that the electronic payment option is only available for those cases for which a demand has been issued, as a demand is considered a formal request for payment of any known and identified conditional payments by the CRC. That is not to say that a payment cannot be made on a conditional payment letter (CPL), but payment on a CPL will not be an option through the portal.
CMS has also created an option for payments to be processed by account holders that may not be the identified debtor. This most often will occur when a retainer or other funds have been provided by the NGHP/debtor to either an attorney or designated recovery agent. Overall, this is an extremely welcomed change that will streamline the conditional payment recovery process, while further reducing the potential exposure to high interest rates associated with untimely payments on conditional payment demands.
We will post CMS’ webinar slides, once the slides have been made available.
To find out how our recovery agent services can be utilized in line with this new MSPRP feature, please contact us at firstname.lastname@example.org.