EO 14247: Modernizing Payments and Medicare Conditional Payment Options

December 16, 2025 / 6 min read

Among the 217 Executive orders issued by President Trump to date in 2025,^[1]one that has drawn interest from a Medicare Secondary Payer (MSP) perspective is Executive Order 14247 (“EO 14247” or “Order”), titled “Modernizing Payments To and From America’s Bank Account”.^[2]

In general, the aim of EO 14247 is to reduce the U.S. Federal Government’s use of paper checks and transition towards electronic payments where possible as more specifically outlined in the Order. As such, the author has received some questions regarding whether this Order will impact a debtor’s current ability to continue to send paper checks to Medicare for conditional payment reimbursement. As outlined below, the author does not anticipate any changes at this time to the Medicare conditional payment reimbursement process related to EO14247 and a debtor’s ability to tender payment using paper checks.

Summary (EO 14247)

EO 14247 identifies the continued use of paper payments (including checks and money orders) by the U.S. Federal Government as a source of unnecessary costs, delays, risk of fraud, lost payments, theft, and inefficiencies and mandates the transition to electronic payments to the extent permissible under applicable law. Except for limited exceptions,^[3] the Order directs executive departments and agencies to phase out paper checks, transition to EFT methods for payments, and process payments to the Federal Government via electronic methods.^[4]

EO 14247 further directs the Secretary of the Treasury and the Secretary of Health and Human Services to “take appropriate action to eliminate the need for the Department of the Treasury’s physical lockbox services” and “expedite requirements to receive the payment of Federal receipts . . . through electronic means.” In addition, the Order directs the Secretary of the Treasury to work with federal agencies, financial institutions, consumer groups, and affected individuals and entities to ensure a smooth transition to digital payments, protect sensitive information, and address financial access for unbanked and underbanked populations.^[5]

Medicare Secondary Payer Considerations

From the author’s experience, EO 14247 has raised questions from some regarding its potential impact in relation to the Centers for Medicare and Medicaid (CMS’s) Medicare secondary payer (MSP) reimbursement payback options, in particular, the ability of debtors to continue to use paper checks to reimburse CMS. To help provide some context, the author first provides a quick general refresher on CMS’s recovery and reimbursement process as follows:

As part of the MSP conditional payment process, CMS utilizes two contractors: the Benefits Coordination and Recovery Center (BCRC) and the Commercial Repayment Center (CRC) to identify and recover Medicare payments that should have been the responsibility of another payer in situations involving liability insurance (including self-insurance), no fault insurance, and workers’ compensation insurance.^[6]

Regarding conditional payment recovery, CMS’s stated policy is to seek reimbursement from the Medicare beneficiary in situations where the Medicare beneficiary has obtained a settlement, judgment, award, or other payment, and seek reimbursement against the insurer (or self-insured entity) in situations where that entity has ongoing responsibility for medicals (ORM).^[7]

To provide a sense of scale, the author notes that in Fiscal Year 2023 (the most recent year for which data is available), the CRC issued 83,523 demand letters, resulting in $260.93 million in collections.^[8]

CMS offers several payment submission options

When CMS issues a conditional payment demand, the letter will advise the debtor of the amount of money owed to Medicare, how to resolve the debt by repayment, and the debtor’s administrative appeal rights. CMS provides several different options for debtors to reimburse Medicare as follows:

Electronic Payment (Medicare Secondary Payer Recovery Portal)

This option is available to authorized parties on the Medicare Secondary Payer Recover Portal (MSPRP). According to the MSPRP User Guide, authorized users may “submit electronic payments for a demand via Pay.gov, a secure government-wide collection portal that processes payments online.” Payments on Pay.gov can be made either via PayPal (linked to a bank account), a debit card, or using bank account information, with payments capped at $10,000 via PayPal, $24,999.99 for debit card payments, and $99,999,999.99 when using a bank account.^[9]

Automated Clearing House (ACH)

Medicare also provides the option for employers, plan sponsors, insurers, third party administrators, and attorneys to enroll in an ACH process with the BCRC and/or CRC to offer electronic payment of conditional payment demands. For more information on this process, please see the author’s prior article here.

Payment by Check

As noted above, the demand letter issued by the applicable CMS contractor will include instructions for payment, including the amount owed, the address for issuing payment, and instructions for making payment. Payment addresses for the BCRC and CRC can also be found on Medicare’s website.

In light of EO 14247 some have raised the question regarding whether CMS’s contractors (BCRC and CRC) will continue to accept payment by check going forward. In this regard, Verisk has confirmed with both the BCRC and CRC that they anticipate no changes at this time with both contractors noting that they will continue to accept payment via check for debtors to satisfy conditional payment demands. Given this, EO14247 is not anticipated to have any impact on conditional payment reimbursement at this time, and parties may still make payment to CMS via paper check.

Questions?

Verisk will continue to monitor and will provide updates if there are any future developments on this topic. In the interim, please do not hesitate to contact the author if you have any questions or if Verisk can be of any assistance.

How Verisk Can Help

Verisk offers several different Medicare recovery services that can help you address CMS conditional payment claims, including our standard Medicare Advantage and Part D recovery services. We also offer our popular CP Link^® program which provides a proactive approach to Medicare recovery claims leveraging your Section 111 data to initiate the conditional payment process. In general, CP Link helps speed up the conditional payment process by identifying potential conditional payment claims through Section 111 data, helps reduce adjuster time, and facilitates a holistic compliance approach to conditional payment claims. In addition, our PAID Act Add-on for CP Link utilizes the PAID Act data to provide a customizable solution for identifying and resolving Part C and D liens.

Through our experienced team, we consistently deliver extraordinary savings for our customers. For example, in 2024, we saved our clients over $160 million in conditional payments, nearly $1 million in Treasury savings, and over $1.7 million in Medicare Advantage lien savings for our customers.

Please do not hesitate to contact the author if you have any questions regarding our Medicare conditional payment services. Also, see our Medicare conditional payment resource center which provides an excellent “one-stop” resource containing resource articles and services information!

[1] https://www.federalregister.gov/presidential-documents/executive-orders/donald-trump/2025

[2] Executive Order No. 14247, 90 FR 14001, https://www.federalregister.gov/documents/2025/03/28/2025-05522/modernizing-payments-to-and-from-americas-bank-account

[3] Id, Section 4.

[4] Id, Section 3.

[5] Id, Section 5.

[6] https://www.cms.gov/medicare/coordination-benefits-recovery/overview/non-group-health-plan-recovery

[7] https://www.cms.gov/medicare/coordination-benefits-recovery/overview/reimbursing

[8] Center for Medicare & Medicaid Services, Annual Report on The Medicare Secondary Payer (MSP) Commercial Repayment Center (CRC), Report to Congress Fiscal Year 2023, July 2024, Section 4. The author wishes to note that the CRC Report to Congress includes both non-group health plan (NGHP) and group health plan (GHP) recovery, but does not provide a breakdown by type. In addition, the author has not been able to locate data regarding BCRC recovery. As such, the numbers cited in the CRC Report to Congress are the best publicly available data to demonstrate the relative scale of Medicare conditional payment recovery.

[9] Id.