CMS held a teleconference regarding MMSEA Section 111 Reporting on September 18, 2012 which pertained to Liability Insurance (including Self-Insurance), No-Fault, and Workers’ Compensation collectively recognized as Non-Group Health Plans (NGHP). During this teleconference, CMS addressed various topics, including, but not limited to MMSEA Section 111 Reporting, the new MSPRC portal (MSPRP), and the implementation of ICD-10 as it relates to reporting.
Please note that this blog only touches on some of the highlights of the CMS Teleconference1 and is not all-inclusive of items discussed during the teleconference. CMS stated that all official guidelines are posted on the Section 111 web page at www.cms.gov/MandatoryInsRep. If there are any conflicts between the documents/information posted on the web site and what is stated on the teleconference, the written documents/information posted on the web site prevail.
Question: In a state where medicals can be re-opened for a set period of years pursuant to state law, if the claim is administratively closed, how does an RRE report the claim?
Answer: Under these circumstances, the RRE would report the TPOC when it occurs along with ORM. When legal responsibility for medicals terminates, the RRE would terminate the ORM. CMS is aware that some claimants are having problems receiving Medicare benefits in these situations due to the RRE reporting ORM on the compensable injuries (appropriate ICD-9 codes provided). CMS recommends that the beneficiary obtain a written statement from their doctor confirming they no longer require treatment for the compensable injuries so that ORM can be terminated.
Question: Does CMS plan to extend access to the MSPRC portal to more than 20 individuals per organization?
Answer: CMS will review the system and look into this further, but at this time cannot do anything about the limitation of 20 users.
Question: What would the TPOC date be in a workers’ compensation claim when the RRE settles a case with an MSA pending CMS approval, and the carrier has the right within the settlement agreement to either fund the MSA as approved by CMS or leave the medical open continuously?
Answer: In this situation there is an indemnity TPOC, plus ORM, and possibly an additional TPOC for the MSA. The RRE would initially report a TPOC for the initial portion of the settlement (indemnity) as well as ORM for the medical while the MSA is pending approval by CMS (if ORM has not already been reported). Once CMS approval of the MSA is obtained, the RRE must determine the appropriate next step. If medicals remain open, ORM also remains open. If the MSA will be funded as approved by CMS, this would be reported as a separate TPOC and ORM would be terminated. The date of the TPOC for the funding of the MSA would be the date that best fits (CMS would treat this as an additional settlement).
Question: When will the change to ICD-10 apply to Section 111?
Answer: The switch to ICD-10 as it pertains to MMSEA Section 111 Reporting will likely be in conjunction with CMS’ deadline, which is currently planned for October of 2014. CMS cannot provide any conclusive statement at this time, but advises the industry to stay tuned for further information related to implementation.
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1. Questions and answers have been paraphrased.
This blog is provided as reference material and is based on verbal information derived from third parties during teleconferences hosted by the Centers for Medicare and Medicaid Services (CMS). PMSI does not assume liability or responsibility for the accuracy or completeness of the material in this document. The information contained herein should not be construed as an endorsement of any kind or an official transcript of the teleconference. PMSI makes no representation or warranties of any kind, either express or implied, that this information is accurate, up-to-date, or error free and PMSI shall not be liable in any amount for any damage, however arising, that may occur as a result of your reliance on this information. This document is advisory in nature only and does not represent official policy, procedures, or opinions of CMS or PMSI. For official information regarding Section 111 of the Medicare, Medicaid, and SCHIP Extension Act (MMSEA), refer to the official web page https://www.cms.gov/MandatoryInsRep/.↩