Commercial Repayment Center (CRC) Update
Heather Sanderson
June 1, 2016

Three months ago, we issued a blog (click here to view) regarding the CRC beginning to issue Conditional Payment Notices (CPNs) and Demands on no-fault and workers’ compensation claims where Ongoing Responsibility for Medical (ORM) had been reported. Recall that back on October 1, 2015, the CRC began to share a portion of the Non Group Health Plan (NGHP) recovery with the Benefits Coordination and Recovery Contractor (BCRC) with letters beginning to issue on October 25, 2015.

It has been no secret that there have been some delays with regard to the implementation of the CRC’s recovery processes. As it stands now in June 2016, the CRC continues to issue some CPNs and Demands; however delays in the process are unfortunately still present. Additionally, some claims are backlogged entirely at the CRC and settling parties are unable to be provided conditional payment information on their claims.

Below we have listed some of the functions that the CRC has worked diligently to resolve and that are now fully functional. The CRC is making progress but additional work is still needed. Additionally, below are some of the issues that are still being seen with CRC cases and have not yet resolved.

Franco Signor continues to engage with the CRC and the Centers for Medicare and Medicaid Services (CMS) on the CRC’s implementation. CMS/CRC is hopeful that as of October 1, 2016, the CRC recovery process will become fully functional.

Resolved Issues:

  1. The Portal now reflects Conditional Payment amounts for newer CRC cases.
  2. Parties can now take advantage of the pre-settlement final demand functionality for CRC cases.
  3. The Portal now allows for disputes on CRC files.

Unresolved Issues:

  1. As mentioned above, CPNs, CPLs, and Demands are backlogged and not currently moving through the CRC’s processes.
  2. CRC is not issuing Final Demands on claims that have terminated ORM w/out settlement.
  3. CRC has issued Demands even though a dispute on the CPN is still in process.
  4. Most CPN disputes are not being responded to timely.
  5. CRC is opening files where the BCRC already has an open file and requested reimbursement.

Please contact us if you have any questions on conditional payments or the Commercial Repayment Center at We will continue to provide updates on the CRC as they become available.

Heather Schwartz Sanderson, Esq., MSCC, CHPE, CLMP, CMSP
Chief Legal Officer
Franco Signor LLC