Background - How a User is Associated with an MSPRP Recovery Case

When a Medicare Secondary Payer Recovery Portal (MSPRP) user first requests access to a recovery case on the MSPRP, the MSPRP tries to match the MSPRP account of the user to an entity that is authorized to work on the case. In most situations, the MSPRP will attempt to match the name and address information for the account on the MSPRP to the name and address of a party currently associated with the recovery case in Medicare's files. In this situation, the MSPRP will use all address information that has been submitted for the MSPRP account in the past, including during initial registration and account setup and any address changes made later. In situations where a recovery case is created from an insurer's Section 111 Non-Group Health Plan (NGHP) claim report made via the Mandatory Insurer Reporting process, the MSPRP will attempt to match the Employer Identification Number (EIN)/Tax Identification Number (TIN) submitted during the MSPRP registration process (for a Corporate account) to the TIN submitted on a Section 111 NGHP TIN Reference File.

Note: A party on the case could be any of the following individuals/entities: the beneficiary's attorney, other beneficiary representative (i.e., family member), insurer, or recovery agent working on behalf of a beneficiary, attorney or insurer.

When a match on the address/TIN is found, the account becomes linked/associated with the case on the MSPRP. Once this link is established, the level of authorization that account can/should have on the case is determined, and appropriate MSPRP functionality for that account is enabled on the MSPRP. Without this link, the functionality of the MSPRP is limited. When a match is not found to an associated party on the case, users associated with the MSPRP account are restricted to the following actions: submit an authorization request, request an updated conditional payment amount on a BCRC case, and request a copy of a conditional payment letter for a BCRC case. Until the user can establish the account as an authorized party by submitting the necessary authorization documentation on the MSPRP, they will not be able to receive copies of correspondence, will not be able to dispute claims, and will not be able to submit notice of settlement information.

Recommended Approach to Submitting Address Information

1. During the initial registration of your new MSPRP account, the AR should submit the email address where you want to receive the post-registration Personal Identification Number (PIN) email. The account ID will be shown in the MSPRP at the end of the new registration process. The AR should also submit the postal mail address where you typically receive correspondence from Medicare about the case(s) in question
2. During the second step of the registration process (account setup) when your Account Manager (AM) submits their personal information, instruct them to enter the same mailing addresses as in step 1. If you have not received any correspondence from Medicare, enter the address where you want correspondence directed. For insurers, this should be the address submitted on the Section 111 NGHP TIN Reference File.
3. After registration and account setup has been completed and your account has been activated, you will be able to request access to a recovery case(s). When you request access to a case, the MSPRP will associate the case to your account and you will be able to view case information on the MSPRP. When you view the case information, check to see if you are authorized for the case (i.e., the Case Information page should show the Authorization Status as Verified for the Authorization Type you submitted). If you do not see the correct Authorization and Status listed, you have two options:
• Verify that your account address stored on the MSPRP matches the address on correspondence previously received for the recovery case. If these two addresses do not match, the AM must update the account address on the MSPRP. You must then wait at least one business day before attempting the Request Case Access action again on the MSPRP.
OR
• Submit/resubmit the proper Beneficiary Proof of Representation (POR), Beneficiary Consent to Release (CTR), or Recovery Agent Authorization. Wait until the status of your authorization has been changed to Verified. Once the authorization request is verified, you will be copied on all case-related correspondence and will be able to perform all applicable actions on the MSPRP related to the case.
For supporting document requirements, see the Authorization Documentation help page.

How to Submit a Permanent Address Change

When you make a permanent address change, it is a multi-step process. Just changing your address on the MSPRP will not automatically change your address on existing cases. You must follow the steps below:

1. Submit the address change on the MSPRP by clicking the Update Account Information link on the Home page. This link will display a page where you can edit the Recovery Case Mailing Address. This action can only be performed by the AM.
2. To associate your new address to existing MSPRP cases, you must also submit the address change to the following addresses:
For BCRC cases, write to: NGHP
PO Box 138832
Oklahoma City, OK 73113
Fax: (405) 869-3309
Phone: (855) 798-2627
For CRC cases, write to: Commercial Repayment Center - NGHP
PO Box 1610
Lathrop, CA 95330
Phone: (855) 798-2627

It is important to provide your old name and address, your new name and address, and a Case ID for your account that is associated with this address change request. Note: insurers/self-insured entities that report under Section 111 not need to complete this step. This information will be sent via the Section 111 TIN Reference File.

3. Insurers/Self-Insured Entities that report under Section 111 must submit an updated Section 111 NGHP TIN Reference File with the new address. This will update the insurer's address associated with existing cases created from Section 111 reports and use the new address on new cases created from Section 111 going forward. However, when the case is created from a self-report, the insurer may need to submit the address change to the address/fax/phone as noted in step 2 above.

Registration and Account Setup Scenarios

The following scenarios are intended to help you decide how to register and work on the MSPRP depending on your level of involvement related to resolving MSP recovery demands. This information is provided as guidance only and is not intended to encompass or supersede any or all of the rules/regulations related to an individual/entity obtaining proper authorization (i.e., POR, CTR, or Recovery Agent Authorization) related to MSP recovery cases.

Beneficiary - No MSPRP Registration Required

Beneficiaries do not need to register to use the MSPRP. A beneficiary will access the MSPRP via the MSP pages of Medicare.gov using their established login ID and password for that application. Beneficiaries are granted full access to their cases and are matched by Medicare ID (Health insurance Claim Number [HICN] or Medicare Beneficiary Identifier [MBI]). Note: Beneficiaries will only be able to view cases that are in an Open status or cases that were closed within the last month.

Representative - Independent Attorney or Other Beneficiary Representative

A Representative account is intended for:

• An attorney who is not part of a law firm, does not have an EIN/TIN, and is representing one or more beneficiaries, or
• A family member, or other individual, who is representing the beneficiary.
During registration, the registrant must submit their Social Security Number (SSN) in order to be validated and permitted to create an account.

Account Representative (AR) & Account Manager (AM) Roles:

Under most circumstances, the AR and AM are likely to be the same person in representative accounts. However, two different people could be designated to each of these roles. For example, the attorney could be the AR and have their paralegal be the AM.

Law Firm Representing Beneficiaries - Corporate Account

A law firm that may represent multiple beneficiaries and work on multiple recovery cases will register as a Corporate account on the MSPRP. During registration, the registrant must submit the corporate EIN/TIN.

Account Representative (AR), Account Manager (AM) & Account Designee (AD) Roles:

In this scenario, an executive or partner of the law firm will likely play the role of AR and designate another attorney, paralegal, or other employee of the firm to play the role of AM. (The AR and AM cannot be the same person for corporate accounts.) The AM would likely invite other attorneys/paralegals/employees as ADs associated with the account. These ADs would likely only work with specific cases on the MSPRP as assigned by the AM.

Recovery Agent or Other Agent Working for Beneficiary/Beneficiary's Attorney

A recovery agent working for a beneficiary or a beneficiary's attorney has two options for registration. The choice depends on whether or not the recovery agent must be copied on all recovery-related correspondence in addition to the beneficiary and attorney. In all cases, the recovery agent and associated MSPRP users must have the proper authorization documentation (POR, CTR, or Recovery Agent Authorization) on file with Medicare in order to work on a particular recovery case.

• Option 1: Recovery Agent Corporate Account - Separate Party Associated to a Case and Copied on Recovery Case Correspondence

In order for the recovery agent to directly receive a copy of correspondence related to the recovery, they must be associated to the recovery case as a properly authorized party. In this situation, the recovery agent would register for a Corporate account using its EIN/TIN and designate appropriate individuals as its AR and AM.

• Option 2: Recovery Agent as Account Designee - No Separate MSPRP Account and Not Copied on Recovery Case Correspondence

If a recovery agent has no need to receive copies of actual correspondence related to a case, the recovery agent would not need its own MSPRP account. Its client would set up the account and have its AM designate the appropriate individuals from the recovery agent as ADs.

Account Manager (AM) and Account Designee (AD) Roles for Option 1 or Option 2:

An AM may be the AM for only one MSPRP account. Therefore, it would probably not be practical for a recovery agent to play the role of AM for any account under this scenario.

The client's AM would invite individuals from the recovery agent to register as ADs.

Note: An AD for one account cannot be an AM for another account. An AD may be associated to multiple MSPRP accounts as long as they are invited to each account by each account's AM. ADs will have one Login ID. Once they login to the MSPRP, they will be presented with a list of accounts to work under based on the accounts they have been assigned by the AM.

Insurer/Self-Insured Entity

An insurer or self-insured entity that wants to work with cases on the MSPRP should register as a Corporate account. During registration, the registrant must submit the corporate EIN/TIN. The TIN supplied during the registration process should match the TIN the insurer submitted on its Section 111 NGHP TIN Reference File. If the insurer uses multiple TINs on its Section 111 TIN Reference File, it is recommended that the insurer complete the new registration and account setup steps to create a separate Corporate MSPRP account for each TIN submitted on its Section 111 TIN Reference File. Note that the Office Code/Site ID used in Section 111 reporting is not submitted on the MSPRP and is not required to associate the insurer with its recovery cases. Only the TIN is used to associate the insurer with its recovery cases.

Account Representative (AR), Account Manager (AM) & Account Designee (AD) Roles:

Each Corporate account must have the appropriate individuals designated as the AR, AM and AD(s). Note that different ARs and AMs must be named for each MSPRP account/TIN used to register.

Authorizations Required:

In order to dispute claims, the insurer must be recognized as the debtor on the case. In other words, the insurer's MSPRP account address must match the insurer debtor address on the case (the address at which the insurer received the Conditional Payment Letter, Conditional Payment Notice, or Demand) or the insurer's TIN submitted during registration must match the insurer TIN associated with a case created from the insurer's Section 111 claim report. In cases where the insurer is the debtor on the recovery case but does not have the proper authorization (i.e., Recovery Agent Authorization) showing on the case in the MSPRP, and the insurer has verified its address and TIN supplied on the MSPRP, the only actions they will be allowed to perform on the case in the portal are: view/submit authorization requests, request an updated conditional payment amount on BCRC cases, and request a conditional payment letter for a BCRC case. If a Recovery Agent Authorization has been submitted and verified, the insurer (or insurer's representative) is then authorized to view and dispute claims for CRC recovery cases. Otherwise, disputes will have to be handled manually rather than on the MSPRP by submitting them to the following addresses:

For BCRC cases, write to:

NGHP
PO Box 138832
Oklahoma City, OK 73113
Fax: (405) 869-3309
Phone: (855) 798-2627

For CRC cases, write to:

Commercial Repayment Center - NGHP
PO Box 1610
Lathrop, CA 95330
Phone: (855) 798-2627

When the beneficiary is the debtor on the recovery case, the insurer will need to resubmit (or submit for the first time) the proper CTR authorization in order to receive a copy of case correspondence. Once the CTR submission is completed (authorization shows as Verified status on the MSPRP), the insurer will be copied on all case-related correspondence.

Recovery Agent or Other Agent Working for an Insurer

A recovery agent working for an insurer has two options for how they should register. The choice depends on whether the recovery agent must be copied on all recovery case correspondence and how its insurer clients submitted their NGHP TIN Reference Files. One option involves setting up a corporate account for the recovery agent and the other involves working as Account Designees under accounts established by insurers. A recovery agent may wish to work under both scenarios, depending on the circumstances. In all cases, the recovery agent and associated MSPRP users must have the proper authorization to represent the insurer in order to work on a particular recovery case.

• Option 1: Recovery Agent Corporate Account - Separate Party Associated with a Case and Copied on Recovery Case Correspondence

In order for the recovery agent to directly receive a copy of such correspondence in addition to the insurer, they must be associated to the recovery case as a properly authorized party. In this situation, the recovery agent would register for a Corporate account. During registration, the registrant must submit their corporate EIN/TIN and name appropriate individuals as its AR and AM. The recovery agent must then submit a POR indicating their authorization to represent the insurer for each case as described previously.

• Option 2: Recovery Agent as Account Designee (AD) - No Separate MSPRP Account and Not Copied on Recovery Case Correspondence

If a recovery agent has no need to receive separate copies of correspondence related to a case in addition to the insurer, it would not need its own MSPRP account. Instead, its insurer clients would set up accounts and the insurer's AM would invite individuals from the recovery agent to register as ADs.

Account Manager (AM) and Account Designee (AD) Roles for Option 1 or Option 2:

• An AM may be the AM for only one MSPRP account. Therefore, it would probably not be practical for a recovery agent to play the role of AM for any account under this scenario.
• The insurer's AM would invite individuals from the recovery agent to register as ADs.
• An AD for one account cannot be an AM for another account. An AD may be associated to multiple MSPRP accounts as long as they are invited to each account by each account's AM. ADs will have one login ID. Once they login to the MSPRP, they will be shown with a list of accounts to work under based on the accounts they have been assigned by the AM.
Note that this scenario of working as ADs under insurer's accounts would be an appropriate option if the insurer submitted its Section 111 NGHP TIN Reference File records with its recovery agent's address as specified in the alert on the Section 111 Mandatory Reporting web site dated December 20, 2011 ("Information on the Submission of TPA Information"). Under this circumstance, the insurer's name and TIN are associated to the insurer on the case, but the recovery agent receives the recovery case correspondence.

Note: When a recovery agent who is representing an insurer submits a Recovery Agent Authorization, the authorization must meet these requirements:
• It must be in writing (that is, signed and dated by both entities).
• It must state that one entity appoints the other entity to act on its behalf.
• It must include purpose and scope (that is, it must describe the reason for the authorization).
• It must include name, phone and address of each entity. (Note: These elements are often already part of the letterhead.)
• It must indicate professional status or relationship between the entities (for example: attorney/client, agency, third-party administrator, etc.).
• It must indicate the recovery case ID, or otherwise provide information that allows CMS' recovery contractor to associate authorization with a particular beneficiary file.
• It must include a timeframe for the agent's authority.
• It must be submitted to CMS' recovery contractor.
Note: If an applicable plan designates an agent electronically via Section 111 reporting, further documentation does not need to be submitted unless the agent needs to request contractor actions after a demand is issued. Actions that occur after a demand is issued include requests for appeal and requests for reopening. (See 42 CFR 405.940 and 405.980) Requests for appeal and reopening will be denied if submitted by an entity other than the applicable plan and we do not have appropriate authorization documentation on file.

Febuary 2023