CMS Issues New MSPRP User Guide

While Americans celebrated Independence Day this week, the Centers for Medicare & Medicaid Services (“CMS”) issued a new Medicare Secondary Payer Recovery Portal (“MSPRP”) User Guide that will hopefully lead to some increased independence and efficiency for the Medicare Secondary Payer community in how they use the MSPRP during the conditional payment recovery process. A copy of the revised guide, version 4.2, can be accessed by clicking here.

The revised guide contains four primary changes:

• A new read-only Letter Activity tab has been added to the Case Information page, which displays correspondence that has been received or letters that have been sent related to a Benefits Coordination & Recovery Center (“BCRC”) or Commercial Repayment Center (“CRC”) case (Section 13.1.1).
• The ability to request electronic conditional payment letters (“eCPLs”) for BCRC and CRC insurer-debtor cases (Sections 13.1.5 and 14.5.4).
• A Last Login Date column has been added to the Designee Listing page to help MSPRP account managers (Section 8.3.2).
• The Primary Diagnosis Code has been added to the payment summary form, in bold, under the DX Codes column, along with an explanatory footnote in cases where Part A, non-inpatient, claims do not have an HCPCS or DRG code associated with them (Table 13-8).

CMS has initiated a most welcome change to the MSPRP with the addition of the Letter Activity tab. This change should be one that provides transparency to the Medicare Secondary Payer stakeholder community as they navigate the conditional payment process. The new Letter Activity tab will serve as a road map by allowing parties to confirm every correspondence type exchanged throughout the recovery process, the date each correspondence was sent or received, and the case status following delivery or receipt of every correspondence. In situations with multiple conditional lien claims, this tab will allow parties to ensure that correspondences were properly received and attributed to the appropriate claim without having to call the BCRC or CRC. Unfortunately, it appears that a pdf copy of the specific correspondence cannot be accessed from the Letter Activity tab, but perhaps this will be available on cases going forward or the new tab can be altered to include additional access in the future. For now, this is a great step to provide all interested parties with a clear and complete picture of the history of the conditional payment process.

Another refreshing addition to the MSPRP is the ability for authorized parties to request eCPLs in certain situations (i.e. when a claim has been processed, is open, a conditional payment has not been issued or pending, etc.). If requested, a pdf displaying the current conditional payment amount is generated and can be printed and/or saved. If the conditional payment amount is greater than zero, the eCPL will include the same information found on a payment summary form, such as the reported diagnoses codes, provider name, dates of service, and conditional payment amount asserted. Compared to requesting a mailed conditional payment letter to obtain documentation, which can take between 7–10 days to be generated and mailed, this new feature offers parties a much faster way to identify and evaluate existing conditional lien charges. The same functionality has been added to permit authorized parties to initiate an electronic final conditional payment letter request.

Although it is clear that these changes may have been made with CMS’ interests in mind, to reduce the number of calls received by the BCRC and CRC, these updates also benefit parties involved in conditional payment recoveries by allowing them to access more information and enabling them to analyze conditional lien claims faster and more accurately. Given the speed with which settlement negotiations can materialize or deteriorate, these upgrades are a welcome addition to the MSPRP and will help facilitate faster resolution of conditional payment recovery issues.

The Dickie, McCamey & Chilcote Medicare Compliance Group is available to help your organization with all aspects of MSP compliance, including the resolution of Medicare conditional payment issues. If you have any questions regarding the information outlined above or any other inquiries, please feel free to contact us.

W. Brian Rambin

Michael D. Bergonzi 412-392-5451 mbergonzi@dmclaw.com