The Commercial Repayment Center (CRC) has been issuing an increasing number of Conditional Payment Notices and demands for reimbursement against insurance carriers and self-insured entities with ongoing responsibility for medicals. The CRC is not supposed to seek collection of claims while an appeal is pending. However, the CRC has been issuing letters while appeals are pending stating that the claims will be referred to the Department of Treasury for collection.
Unfortunately, the CRC has stated that notices of intent to refer claims to the Department of Treasury will automatically be issued regardless of whether an appeal is pending. However, the CRC has confirmed that claims will not be referred to the Department of Treasury until after any pending appeal is processed and only if the appeal is denied. In a November 17, 2016, teleconference, the CRC stated the following:
The CRC received questions regarding the overlap of the redetermination process with the Intent to Refer debt to Treasury or ITR process and the referral to Treasury process. ITRs must be issued within 120 days of the date of the Demand letter regardless if there is an open post- demand redetermination for the case. The CRC issues the ITR letter as a reminder that if the debt is not paid or post-demand redetermination is not found to be favorable the case will be referred to Treasury as of 180 after the Demand letter date. The CRC may issue an Intent to Refer letter while a redetermination request is still open, but the CRC will not refer case to Treasury until all correspondence is reviewed and processed. Please be assured that we will work all correspondence for a case before referring the debt to Treasury.