Blog, Legal/Legislative News, Medicare Advantage Part C

The Wild Wild West of Medicare Advantage Organizations (MAOs) filing litigation nationwide against primary plans (workers’ compensation, liability or no-fault carriers/plans) to establish the right to a Medicare Secondary Payer (MSP) private cause of action for failure to reimburse the MAO for unreimbursed conditional payments continues. As of our last update, both the 3rd Circuit (encompassing New Jersey, Delaware and …

Blog, Medicare Conditional Payments

As a continuing effort to update our readers on the Commercial Repayment Center (CRC), we are providing an update on the CRC’s recovery activities. Franco Signor has been notified that several large insurance carriers have received preliminary notice of a large number of potential debts that the CRC intends to issue Conditional Payment Notices (CPNs) or Demands on. Recall that …

CMS Updates NGHP User Guide with Minor Changes

08 Jul 2019 Heather Sanderson No Comments

Blog, Legal/Legislative News, Medicare Secondary Payer News

As of July 1, 2019, CMS updated its NGHP User Guide to Version 5.6 with Minor Changes. A list of the changes made in the new Guide can be found here. Additionally, the updated Guide can be found at Contact us with any questions at

Blog, Legal/Legislative News

Over the last several years, we have been providing updates regarding False Claims Act (FCA) litigation, filed both in Federal and NJ court, against Progressive Insurance Company, wherein a whistleblower, a private citizen, asserted that Progressive was not checking Medicare and Medicaid status of its members prior to enrolling them in their health first automobile insurance policies. By not checking …


Earlier this year, we blogged about CMS updating its WCMSA Reference Guide. Specifically, we pointed out that CMS for the first time included explicit examples in which the settlements would not meet CMS’ Review Threshold for review of a proposed WCMSA, but which would still require consideration of Medicare’s interests. The first example involved an under-threshold Medicare beneficiary settlement, and …

Blog, Legal/Legislative News, Medicare Conditional Payments, Medicare Secondary Payer News, Pharma Part D

Several of our clients have been experiencing an increase in conditional payment letters from Medicare Part D prescription drug plans. Historically, Part D plans have been less active in recovery of conditional payments than traditional Medicare or Medicare Advantage Part C plans; however, the tide appears to be changing. Why are Part D Plans recently increasing their recovery efforts? One …

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