Medicare Mandatory Reporting Timelines Revised and Quick Reference Guide


March 29, 2010 CMS issued a Revised Quick Reference Guide for MMSEA Section 111 Registration (updated Oct. 7, 20131) For Responsible Reporting Entities. But note that CMS cautions everyone that you must read the full updated User Guide.

Q: Why does Medicare supply a 43 page "User Guide" to mandatory claim reporting?
Answer: because the full updated User Guide to Mandatory Reporting (Ver 4.0) updated (Oct. 7, 2013) takes up 463 pages broken down into .pdf sub-parts on the CMS website.

It is anticipated that yet even more changes will be forthcoming but for the most part, most of the gross outline of the claim reporting process, the required data elements and the main provisions have taken shape. There have been substantial changes in this updated User Guide edition in response to industry concerns most notably in regard to who is considered to be a reporting entity (RRE) and in dealing with companies that have a deductible in their workers comp policy.

More CMS Town Hall tele conferences are scheduled for later this year up through June 30,2010 to address even more questions and more industry concerns. Because this changing area of law and the actual requirements are still unfolding, either check with an experienced Illinois workers compensation attorney with questions on where to look for answers or hire a specialized consultant in Medicare Secondary Payor requirements that can closely monitor this specialized area for precise reporting compliance.

If you have reporting responsibilities at your company, you should continue to monitor the CMS page on MMSEA very closely for any new developments and monitor the CMS page for Liability Insurance and Workers' Compensation Reporting for the most up to date information.

Chicago Workers Comp Attorneys -- 3-31-10


Illinois Medical Fee Schedule FAQ and Guidelines 2010


The Illinois Workers Compensation Medical Fee Schedule has been supplemented with answers to FAQs generated from recent fee schedule seminars around the state. As a result of common questions posed by the medical community and workers compensation payers, the Commission issued updated Medical Fee Schedule Instructions and Guidelines ( 1/25/10) for treatment occurring after 2/1/09 and they issued a new list of common Medical Fee Schedule FAQs (1/25/10) that were generated directly out of the seminars.

Naturally, the fee schedule generated a lot of interest from hospitals, treating doctors and the health care providers from the community at large. I share the above links for obtaining updated information that may help workers compensation health care professionals in answering some of their more common questions.

If your representatives were unable to attend the official medical fee schedule seminars, the Medical Fee Schedule Power Point presentation can be found here.

Many answers to medical bill questions were already posted on the Illinois Workers Compensation Commission web site found at “Frequently Asked Medical Questions” . Whenever providers or payers have a medical questions, they are encouraged to check this page first.

These detailed billing questions are often outside the normal knowledge of Illinois workers compensation attorneys as they often relate to very specific billing and payment issues. For example, the updates address correct billing modifiers for bilateral procedures. Not your usual type stuff. While our Chicago workers comp attorneys may not know the answer, we often know where to look or who to ask. As yet another uncommon example, the MS-DRG crosswalk is available online here but the Illinois Workers Comp Fee Schedule incorporates the new MS-DRG hospital inpatient codes for treatment after 6/30/09.

We were just recently asked by a physician at what point can they start charging statutory interest at 1% per month on the unpaid balance of their bills?

That answer is contained in Question # 61 in the updated FAQs. Answer: The medical providers can start charging interest on unpaid amounts after 60 days from the date that the workers compensation payer receives "substantially all of the information necessary to adjudicate the bill".

The exact data elements are not specified in the fee schedule but a workers compensation carrier can certainly argue that interest does not apply if customary billing information is missing. All normal relevant information should be completely filled out on the standardized bill.

The Commission acknowledges that the medical fee schedule guidelines and FAQ cannot address all of the possible questions that might arise in practice but they hope that the parties will continue to use common coding procedures and follow common reimbursement practices to fill in any of the blanks that are not explicitly specified in the guidelines or instructions. You can email your remaining fee schedule questions to feeschdquestions.wcc@illinois.gov

If a dispute continues to exist after reviewing all of the answers provided, the only way for a medical provider to get an official ruling from the Commission is for the employee's attorney or for the employer's attorney to take the issue to trial before an Arbitrator. That arbitration decision can then be subject to an appeal for further review by a panel of the Commissioners who will decide disputed cases for the official ruling of the Commission.

We hope the above links will provide helpful answers our doctors, medical providers and payers while the industry continues to adapt to the new fee schedule changes, requirements and procedures.

Chicago Workers Compensation Attorneys -- 03-02-10