CMS has released a technical alert dated November 10, 2014 related to changes in the TIN file layout and associated TIN response record that will allow an RRE to include a third party administrator (TPA) as a “recovery agent” in the reporting process. CMS had previously allowed a workaround to allow for TPA addresses in the RRE address fields and provided specific guidance to how that data should be submitted.
This alert modifies the workaround process by adding recovery agent name and address fields to the TIN file layout. Corresponding fields have also been added to the TIN response layout and error codes have been created to communicate issues with data submitted in the new fields.
Some important points related to this change are defined as follows in the alert:
- The submission of recovery agent information will remain optional, and the current workaround for submission of a “Third Party Administrator (TPA) Address” should no longer be used. RREs are encouraged to use the new reporting methodology as both the RRE and recovery agent will be copied on recovery correspondence.
- These fields should not be used to submit information for a reporting agent who only assists the RRE with their Claim Input File submissions. These fields should only be used to provide the name and address for an agent assisting the RRE with the recovery process.
- If Recovery Agent Information is included on the RRE’s submission, all recovery correspondence associated with Section 111 claim reports with the same RRE ID, TIN and Office Code/Site ID combination as that submitted on the matching TIN Reference File Record will be issued to the RRE using the address provided and a copy shall be sent to the Recovery Agent using the address provided in the new fields.
- If Recovery Agent Information is not included on the RRE’s submission, all recovery correspondence associated with Section 111 claim reports with the same RRE ID, TIN and Office Code/Site ID combination as that submitted on the matching TIN Reference File Record will be issued to the RRE using the address provided.
- For purposes of MMSEA Section 111 NGHP submission of Recovery Agent information only, CMS will utilize the designation of an agent and submission of that agent’s name and address on the TIN Reference File/DDE Submission, as an authorization by the RRE for the agent to resolve any recovery correspondence related to claim submissions with a matching RRE ID, TIN and Office Code/Site ID combination. CMS will consider the RRE bound by the agent’s actions on such matters. The RRE still retains ultimate responsibility for adhering to Section 111 mandatory reporting requirements and all other MSP obligations and requirements.
- RREs are advised to submit updated TIN Reference File Records after the implementation of the new Recovery Agent fields in July 2015 in order to replace records previously submitted using the “TPA workaround.”
CMS has scheduled this change to be effective in production on July 13, 2015.
Helios believes this change will enhance our capability to provide seamless MSP compliance solutions to our clients, and we will be providing further updates to clients and Section 111 data sources as modifications to MedicareConnect are developed to support this alert.
This alert can be found at the following address: http://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/Downloads/New-Downloads/Technical-Alert-Option-for-RREs-to-Submit-Recovery-Agent-Information-for-MSP-Recovery-Related-Correspondence-.pdf
For more information, please contact Frank Fairchok, Senior Manager of MedicareConnect at Frank.Fairchok@helioscomp.com.