On August 9, 2019, the Commercial Repayment Center (CRC) held an industry conference call and announced it was under mandate to reduce the current backlog of 338,819 conditional payment leads.  Instead of inundating the industry with hundreds of thousands of Conditional Payment Notices (CPNs), the CRC plans to ask Responsible Reporting Entities (RREs) to update their Section 111 data.  By providing current information, the CRC believes it can target letters to those claims that are appropriate for recovery.

We applaud the CRC for moving forward with this innovative approach.  RREs can avoid unnecessary letters now by updating Section 111 data to either populate ORM termination dates that maybe missing, delete inaccurate claims, enter TPOC amounts; or clarify ICD codes.  This process while tedious at onset will increase accuracy of the data and mitigate against Civil Monetary Penalties, that the Centers for Medicare & Medicaid Services (CMS) plans to implement through regulation later this year.

Because the expected volume of letters will increase in the next few months, the CRC plans to issue Conditional Payment Letters (CPLs) for the backlogged claims.  This benefits RREs as such letters are not considered debts, and thus no time-line is triggered by which such debts must be referred to the Department of Treasury.  The RRE can then work to properly adjust the debt through the normal dispute and appeal processes, and when ready request a CPN.

However, don’t expect CPLs to issue immediately.  The CRC first plans to send to RREs and RRE recovery agents, pre-CPN worksheets that lists the current outstanding leads.  The CRC intends to provide a time-line (about 35 days) for those spreadsheets are returned with information on which claims Section 111 data was updated and will hold processing any letters for those claims until the RRE reports the updated data to CMS.  Only those matters that do not require any data updates will be processed to a CPL or CPN.  This process should manage the volume and allow the CRC to systematically reduce the backlog.

The CRC next industry conference call is 9/9/2019 and we will update you on any changes.  In the interim, if you have any questions or comments, please contact us at engage@francosignor.com


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