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Update: Changes to Conditional Payment Claim Recovery Process

In October, a new contractor, the Commercial Repayment Center (CRC), began handling conditional payment claim recovery for claims in which CMS is pursuing recover directly from the primary payer.

As you might imagine and may have already experienced, the new contractor has brought many changes to the conditional payment claim recovery process. One of those changes concerns the authorization required for the CRC to provide information to an applicable plan’s agent and has been the source of many questions. The CRC is requiring an authorization (referred to as a Letter of Authority or Proof of Representation) that allows them to confirm that the agent is authorized to work on behalf of the applicable plan- the liability insurer, no-fault insurer, or workers’ compensation insurance carrier or self-insured employer- and this authorization must come from the applicable plan itself. While previous Medicare contractors have accepted authorizations from an applicable plan’s third party administrator, unfortunately, the CRC will not accept an authorization from a third party administrator.

An agent can still obtain information from the CRC with an authorization form signed by the claimant. However, a Letter of Authority/Proof of Representation from the applicable plan is required for an agent to take any action, such as filing a dispute or appeal, on the plan’s behalf. Due to the limited timeframes for filing of disputes and appeals, it is critical for agents to have an authorization that allows them to act on the applicable plan’s behalf.

We will continue to monitor changes in the conditional payment claim recovery process and make sure you are aware of all important developments. Please let us know if you have any questions regarding this recent change.

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