CMS is responsible for ensuring that Medicare only pays for those services for which it is responsible. It relies upon its umbrella “organization” the Coordination or Benefits & Recovery (COB&R) to ensure that this goal is met. There are then several agencies within this umbrella that assist in carrying out the recovery efforts of CMS and the COB&R to ensure that any payments that should be reimbursed are in fact properly recovered.
BCRC: The Benefits Coordination & Recovery Center (BCRC) is responsible for ensuring that Medicare is repaid for any conditional payments (liens) made that are related to a liability, no-fault, or workers’ compensation case. However, for practical purposes, the BCRC largely has become the recovery agent in liability claims.
CRC: This is because the Commercial Repayment Center (CRC), as of 2015, took control of recovery of conditional payments (liens) where the debtor is identified as an insured/workers’ compensation entity. Therefore, for all practical recovery purposes, where recovery is found in the insured/self-insured/carrier, as it is in a workers’ compensation claim, the CRC handles recovery. (The BCRC still holds pre-2015 WC files and certain select cases.)
What is interesting to note is that Medicare utilizes outside vendors for this work. Thus, every few years we see a transition in the management of the team behind the BCRC/CRC or WCRC (Workers’ Compensation Review Contractor) name.
As of February 12, 2018 we have a new Commercial Repayment Center (CRC) Contractor handling Medicare “lien” work, Performant Recovery, Inc.
Specifically, the new CRC vendor will be responsible for handling Non-Group Health Plan ORM (Ongoing Responsibility for Medicals) lien work. Typically we see ORM responsibility only with workers’ compensation matters as this relates to files where the payer has an ongoing responsibility to pay for medicals associated with the claim.
The current address and fax for NGHP ORM under Performant Recovery is:
Medicare Commercial Repayment Center – NGHP
P.O. Box 269003
Oklahoma City, OK 73126
Fax: (844) 315-7627
Only time will tell if there are any significant changes under the new CRC vendor’s leadership. However, here is the good news: we seem to be seeing an increase in activity that we have not seen in several years. Under the previous vendor we simply did not see “file closure” or “lien satisfaction” letters in workers’ compensation cases where a prior $0 Conditional Payment Letter (CPL) had been issued. Clients would wait quite some time, and while our partners were able to provide a $0 screen shot from the on-line web portal, it became quite a challenge, if not impossible to get the CRC to issue a formal closure letter.
Now, just a month after the new vendor has taken the reigns, we are seeing case closure letters on several of these older files. Hopefully this is not an anomaly, but a new process this vendor is putting back into place.
One thing that we would caution with the new vendor is that they are very precise in their process and the data that they will and will not accept. When attempting to secure information regarding conditional liens ALL information must be reported exactly as it is in their system.
For example: a prior or partial address cannot be utilized. The parties must report the current and exact address. Full names, dates of injury and dates of birth must be precise. The vendor does not allow for any inaccuracies. This can delay a claim if a claimant has moved during the course of their case or is using a hyphenated last name.
Additionally, when seeking a lien satisfaction/case closure letter, the new CRC vendor is requiring that the Responsible Reporting Entity (RRE) for Section 111 reporting purposes, ensure that the final ORM termination date is reported in the Section 111 electronic reporting system. This means that upon resolution of a claim, whichever entity is reporting Section 111 information (carrier, self-insured, TPA), that party must first ensure that ORM term dates are quickly and correctly reported so that a final lien satisfaction or closure letter can be obtained.
Thus, while we are generally finding the transition to be a smooth one, we also do caution that in an effort to save time in seeking lien information it is perhaps best to ensure all information is up-to-date prior to attempting to secure conditional payment information via this new CRC vendor.
Atlas Settlement Group, Inc.
Medicare Compliance Services
3565 Piedmont Road NE
Building 1, Suite 525
Atlanta, GA 30305
Office: 404-926-4160 x215
Email: Natalie Clark
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