Tuesday, August 31, 2010

New primary payment notice process implementation with BCBSNC

The Medicare Secondary Payer Recovery Contractor (MSPRC) is implementing a new Primary Payment Notice (PPN) process, effective this month, to improve the accuracy of Medicare Secondary Payer (MSP) demands. On August 30, the MSPRC will begin issuing PPNs ahead of MSP Demands, to both the impacted employer and the insurer/TPA.

What is a Primary Payment Notice?
The Primary Payment Notice, or PPN, is a notice to employer groups to advise them that the Centers for Medicare & Medicaid Services (CMS) has identified instances where Medicare may have mistakenly made a primary payment when other primary insurance exists. Enclosed with this notice is a PPN worksheet that lists Medicare beneficiaries and corresponding coverage dates. The notice requests employer groups to review the worksheet, make corrections and additions as necessary, and mail or fax the completed worksheet to the MSRPC.

BCBSNC will also receive a copy of the PPN notices and worksheets that our employer groups receive.

What will BCBSNC do with the copy of the PPN notices they receive from the MSRPC?
BCBSNC will complete the worksheet (review the form, check the "insurer" box, and enter the appropriate information), and we will fax or mail it in to the MSRPC. BCBSNC will work with employer groups to ensure that the worksheets we submit are correct.

What will occur if employer groups do not complete and return the PPN worksheets to MSRPC?
If employer groups do not complete and return the worksheet to the MSPRC within 45 days of the issue date of the letter, a demand (referred to as a Medicare Secondary Payer demand) will be sent for repayment for all of the claims associated with the beneficiaries and corresponding coverage dates identified in this notice.

The PPN is considered a courtesy before a demand is issued and is not considered a valid, documented defense to a MSP demand.

Does the MSPRC require that both copies of the PPN worksheets (the copies sent to both the employer and BCBSNC) are completed and returned?
No; MSPRC does not require both copies.

Can employer groups send their PPN worksheets to BCBSNC, so that BCBSNC can submit the PPN worksheets on the group’s behalf?
Yes; employer groups can do this; however, BCBSNC encourages employer groups to complete and send these worksheets to the MSPRC. Employer groups can contact BCBSNC, so that they can verify coverage information and assist employer groups in completing these worksheets.

As always, the MSP mailbox, MSP.ReqCorrsub@bcbsnc.com, is available to employer groups for status requests, questions, and correspondence submissions.

My employer group just received a PPN and PPN worksheet from the MSRPC. What should the employer group do?
Employer groups should review the worksheet, make corrections and additions as necessary, and then contact BCBSNC, so that they can verify coverage information. Employer groups should then mail or fax the completed worksheet to the MSRPC.

Key points about the PPNs and PPN worksheets:
• A PPN worksheet should be reviewed by both the insurer and the employer and completed within 45 days from date of letter. This will ensure all parties involved in the process are aware of the data being reported to the COBC (Coordination of Benefits Contractor). The certification statement on the PPN worksheet must be completed and signed in order for the COBC to report changes to the COBC. The PPN Worksheet does not have to be signed by both the employer and insurer, but the MSPRC would like to receive both copies from insurer and employer.
• The MSPRC will report changes to the COBC on the employer’s and insurer’s behalf, based on the PPN received.
• A PPN cannot be accepted once a MSP Demand has been issued and will not be reported to the COBC by the MSPRC. In addition, responding to the PPN does not mean that a MSP Demand will not be issued.
• An employer's response that the Insurer/TPA has authorization to respond on the employer's behalf is not a valid response to a PPN.
• Employers must report current and accurate information to the insurer regularly.
• Employers must provide the Insurer with a correct address for MSP correspondence and Section 111 reporting.
• The MSPRC will not acknowledge or respond to the PPN.
• PPNs only serve as verification of coverage.
• The MSPRC will accept PPNs by fax and mail. The MSPRC will not accept PPNs by phone.
• The MSPRC will be reducing MSP Demand issuance while rolling out the PPN program for the next few months.

For more information, click to view the MSPRC Presentation and Sample PPN.

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