Addition of Open Debt Report Function to the Medicare Secondary Payer Recovery Portal (MSPRP) and Two New Portal User Guides Issued

CMS, Conditional Payments, Medicare Secondary Payer Recovery Portal, MSP News on October 8, 2019
Posted by Jean S. Goldstein, JD

You may have seen our blog post on Friday, regarding an alert from the Centers for Medicare & Medicaid Services (CMS) regarding two upcoming webinars to highlight a new electronic attestation feature on the Workers’ Compensation Medicare Set-Aside portal.  CMS also issued an alert on Friday morning regarding an additional enhancement to the Medicare Secondary Payer Recovery Portal (MSPRP).  Yesterday, the MSPRP was enhanced to allow for users of the portal to view an ”Open Debt Report.”  The open debt report page shows the status for open debts in demand status (with data refreshed nightly), for Non-Group Health Plans (NGHP) insurer-debtor cases.  The report is created per Account ID and is visible and available to MSPRP Account Managers only, and lists the following information:

  • Case ID
  • Insurer Name
  • Insurer TIN
  • Recovery Agent/TPA Name
  • Recovery Agent/TPA TIN
  • Beneficiary First Name
  • Bene Last Name
  • Demand Letter ID (Correspondence ID)
  • Demand Letter Date
  • NGHP Claim Number (from Lead, or otherwise blank)
  • Original Demand Amount
  • Current HIGLAS Balance (From Healthcare Integrated General Ledger Accounting System)
  • Current Status of Debt (From Healthcare Integrated General Ledger Accounting System)

For cases to appear on the available report, the accounts receivable (AR) balance must be greater than zero and the Account ID must be linked to the debtor on the case.  This means that either a proper authorization for an entity to act as an authorized agent must have been received by CMS, or an entity must be serving as a Recovery Agent.   The report can be narrowed down with a demand date range, and can be exported to excel.   CMS has also released a new MSPRP user guide highlighting the open debt report, which can be found here.

The open debt report is certainly useful in providing a visual representation of the claims which are in the demand status, or when payments on a Medicare Conditional Payment are technically due.  However, with conditional payments it is critical that payments are handled through established proactive processes prior to the demand phase in order to avoid unnecessary costs, undue delay, and potentially locking a primary payer in as the debtor.  With a uniformed proactive process a primary payer can mitigate exposure early on, prior to a conditional payment entering the demand status.  Nonetheless, the open debt report will be a helpful tool to identify unaddressed or outstanding conditional payments, prior to referral to the U.S. Treasury or other collection activities ensuing.

Recovery Efforts are Increasing

Of significant note, CMS has advised industry stakeholders that 1000 Conditional Payment Notices are being sent weekly, which is a significant increase from the amount of letters sent at this time, last year.  The translation is that recovery efforts are increasing.  With increased recovery efforts on the horizon, this may an opportune time to consider designating a Recovery Agent.  A Recovery Agent is an entity or organization that will receive, directly from the CMS contractor, copies of all conditional payment recovery correspondence associated with an applicable plan.  Designating a Recovery Agent ensures that a named agent will receive all conditional payment recovery correspondence automatically, and therefore be able to timely, and efficiently respond to all recovery efforts within the required time frames, prior to claims being entered into the demand status. 

In addition to the new MSPRP user guide, CMS also released Version 5.9 of the Workers’ Compensation Medicare Set-Aside Portal (WCMSAP) User Guide.  The major changes within the guide fall in line with what we saw in CMS’ recent alert regarding the new portal enhancement regarding electronic attestations, which we blogged about last week.  Specifically, within the new WCMSAP user guide, CMS indicated that in order to reduce the need for paper processing of submitted attestations, the WCMSAP now allows Self and Representative account users, and beneficiary self-administrators logging in via MyMedicare.gov to submit annual attestations online.  In addition, there is a new account type for Professional Administrators, which allows for the submission of WCMSA account transactions via input file submissions.  Per CMS, this will enable professional administrators to provide detailed records for a WCMSA account without the need for submitting an attestation.  Ultimately, the goal appears to enable CMS to track the expenditures made on each WCMSAP in an effort to determine when a WCMSA account has been properly depleted. 

Overall, CMS appears to be finding various methods to enhance and streamline processes.  We will be sure to update our readers on any challenges encountered with these enhancements, as well as any benefits.