Compliance

Conditional Payment Updates | Open Debt Reports are back; Pre-PCN worksheets are on hold; and CRC will continue to review all CPL disputes

There has been a flurry of recent activity from the Centers for Medicare and Medicaid Services (CMS) and the Commercial Repayment Center (CRC) regarding processing of conditional payment claims.  The new CMS and CRC...

CMS’ Section 111 Penalty Proposals Are One Step Closer

A new release from the Office of Information and Regulatory Affairs (OIRA) indicates that the Centers for Medicare and Medicaid Services (CMS) is one step closer to releasing its much-anticipated Section 111 reporting...

The new indemnity data call – are you ready?

As the fourth quarter settles in, a big change is lurking around the corner: The National Council on Compensation Insurance’s (NCCI) new indemnity data call.  Introduced last year, this initiative is scheduled to laun...

Seventh Circuit bypasses Medicare Advantage “double damages” question

The latest case addressing whether the Medicare Secondary Payer’s (MSP) private cause of action (PCA) statute [1] applies to Medicare Advantage Plans (MAP), thereby allowing MAPs to sue for double damages,” reached th...

Massachusetts court: Medicare Advantage Plan’s assignee can sue for “double damages” under the MSP

In an interesting new case out of Massachusetts, the United States District Court in MSP Recovery Claims Series LLC v. Plymouth Rock Assurance Corporation , 2019 WL 3239277 (D. Massachusetts, July 18, 2019) found that...

CMS releases new NGHP Section 111 User Guide (Version 5.6)

The Centers for Medicare and Medicaid Services (CMS) has released an updated Section 111 User Guide (Version 5.6, July 1, 2019 ) regarding non-group health plans (liability, no-fault and workers’ compensation). This...

Medicaid Expansion Makes Recovery Efforts More Urgent

Created in 1965 to provide health care coverage to low-income individuals, Medicaid is now a massive program that provides insurance to one out of five Americans, including adults, children, pregnant women, the elderl...

Think about Your Thresholds: Preventing Errors to Avoid CMS Penalties

We’ve been taking a look at some of the ways RREs can attempt to achieve full CMS compliance and avoid potential penalties that may be coming soon. One area to consider more closely is file thresholds. Upon submission...

Big reforms are coming to Michigan PIP - How the changes will impact Medicare Secondary Payer compliance

On May 30, 2019, Michigan Governor Gretchen Whitmer signed into law Michigan Senate Bill 1 (S.B. 1) [1] which makes significant changes to Michigan’s personal injury protection (PIP) system, including allowing policy...

Florida court: No-fault pre-suit notice requirement must be followed before Medicare private cause of action claim can proceed

Over the past several years, there has been an increasing number of lawsuits filed by Medicare Advantage Plans (MAPs) against insurers seeking “double damages” under the Medicare Secondary Payer (MSP) statute’s privat...