CMS Moving Toward Full Paperless? January Update to NGHP Section 111 Reporting User Guide

Yesterday, the Centers for Medicare & Medicaid Services (CMS) published an updated NGHP User Guide (version 6.7). Chapters I – III of the NGHP User Guide remain unchanged, but Chapter IV (Technical Information) and Chapter V (Appendices) includes updated language regarding a “Go Paperless” option for insurers and recovery agents receiving Medicare correspondence.

NGHP User Guide (version 6.7) – Chapter IV: Technical Information

When there is an active Medicare Secondary Payer Recovery Portal (MSPRP) account for the insurer/recovery agent TIN, Section 111 submitters may set Go Paperless options (i.e., choose to receive letters electronically or by mail) for the insurer and recovery agent address using the TIN Reference File (Sections 6.3.1.1 and 6.3.3).

NGHP User Guide (version 6.7) – Chapter IV: Appendices

When there is an active Medicare Secondary Payer Recovery Portal (MSPRP) account for the insurer/recovery agent TIN, Section 111 submitters may set Go Paperless options (i.e., choose to receive letters electronically or by mail) for the insurer and recovery agent address using the following new TIN Reference File fields (Appendix B):

• TIN/Office Code Paperless Indicator (Field 23)

• Recovery Agent Paperless Indicator (Field 24)

• Recovery Agent TIN (Field 25)

Note: There are also five new fields (Fields 48-52) returned for these entries on the TIN Reference Response File (Appendix D).

Sanderson Firm Commentary: Insurers and their representatives have been able to submit conditional payment disputes and appeals electronically to Medicare for nearly a decade now. They have also been able to view Medicare correspondence online via the Medicare Secondary Payer Recovery Portal (“MSPRP”) (subject to Multi-Factor Authentication access); however, this new update allows insurers to notify Medicare via Section 111 of their request to electronically receive claim-related conditional payment correspondence.

Industry stakeholders will, no doubt, appreciate Medicare’s flexibility and willingness to modernize the recovery process, especially considering that it will streamline administrative handling for insurers and their recovery agents. Insurers and their recovery agents are much more likely to appropriately (and timely) address electronic correspondence instead of sorting, scanning, and filing hard copies of conditional payment correspondence. As an additional benefit, insurers that opt for “paperless” will eliminate instances where Medicare inadvertently mails conditional payment correspondence to the incorrect insurer or recovery agent mailing address.

Sanderson Firm serves as a Recovery Agent for workers’ compensation, general liability, and no-fault insurers, and we are equipped to receive Medicare correspondence both electronically and through traditional mailing. Additionally, Sanderson Firm handles all levels of conditional payment appeals from the contractor, to the QIC, and Administrative Law Judge (ALJ), including appeals based upon Medicare administrative error (i.e., incorrect mailing address).

For assistance with Section 111 inquiries, requests for our conditional payment services, or any questions regarding this post, please do not hesitate to contact us.