by Frank Fairchok, Vice President of Medicare Reporting Services

The Centers for Medicare & Medicaid Services (CMS) published an update to the NGHP User Guide on January 10, 2022, which introduces a paperless option for Responsible Reporting Entities (RREs) and their Recovery Agents to receive recovery correspondence. The summary of updates to User Guide Version 6.7 states:

“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).”

All changes for this update are contained in Chapters IV and V of the User Guide, and include the following modifications to the TIN portion of the file exchange specification:

  • TIN Reference File Detail Record – three additional fields have been added to the “Reserved for Future Use” area of the TIN Detail Record as follows:
    • TIN/Office Code Paperless Indicator (Field 23)
    • Recovery Agent Paperless Indicator (Field 24)
    • Recovery Agent TIN (Field 25)
  •  TIN Reference Response File Detail Record – five additional fields have been added to the “Reserved for Future Use” area of the TIN Reference Response Record as follows:
    • Submitted TIN/Office Code Paperless Indicator (Field 48)
    • Applied TIN/Office Code Paperless Indicator (Field 49)
    • Submitted Recovery Agent Paperless Indicator (Field 50)
    • Submitted Recovery Agent TIN (Field 51)
    • Applied Recovery Agent Paperless Indicator (Field 52)
  • Appendix F: Disposition, Error, and Compliance Flags – Four new error codes have been added to Table F-5, the TIN Reference Response Error Code Resolution Table. These new codes are TN37, TN38, TN39 and TN40 and identify issues with the data submitted in the TIN Detail Record.

Commentary
CMS is making a solid stride forward by introducing a “Go Paperless” option to the recovery process with these technical changes. The Conditional Payment Letters and Notices have always been heavy on paper usage. Having this option is good for the environment and will reduce storage and scanning requirements for those processing these documents. However, it is interesting to note that no “Technical Alert” was issued for these changes, nor does the User Guide provide much guidance around the usage of this functionality. As of the posting of this article, the Benefits Coordination & Recovery Center (BCRC) has confirmed that these changes are live in production within the reporting process.

This update to the NGHP User Guide was made in parallel to an update to the Medicare Secondary Payer Recovery Portal (MSPRP) User Guide. MSPRP User Guide version 5.3 was also released on January 10, 2022 and includes changes that support the “Go Paperless” functionality CMS is rolling out.

Technical Considerations
The additional fields in the TIN Detail Record are optional and spaces are allowed if no values are submitted. This should mean that the submission of TIN data to CMS would not be impacted if a submitter does not change the layout.

While it is not clear from the update, we have also confirmed that filler space should be returned in the response file if nothing is submitted in the detail record. Although it appears this update should not impact RREs unless they choose to implement the changes, our recommendation is for submitters to observe their processes to confirm all functionality remains intact.

If you have questions regarding Mandatory Insurer Reporting please contact us at [email protected]