Allan Koba Compliance Solutions is the premier MSA, Section 111 Audit and Conditional Payment Resolution service provider. We focus on balancing clients' needs with Medicare Secondary Payer demands in a manner that saves time and money. Our promise is to deliver effective solutions in a prompt, clear and efficient manner.

Our Blog

New Re-Review Guidelines added to the WCMSA Reference Guide Version 3.8

On November 14, 2022, CMS released version 3.8 of the WCMSA Reference Guide. If you attended The National Medicare Secondary Payer Network 2022 Annual Conference in September, you may have been anxiously anticipating the release of this updated guide with the hope that clarification on re-review requests would be provided as CMS agency officials discussed these changes would be coming soon. Christmas has come early as CMS has provided clarification on re-review requests and made some changes. Specifically, CMS has added a new category entitled "Submission Error". Submitters may not submit re-review requests where the documentation originally submitted contained errors that resulted in a discrepancy in pricing of no less than $2,500. This new category and specific guidelines surrounding the same can be found in Section 16.1 and 16.2 of the WCMSA Reference Guide.
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Medicare Recovery Efforts May Increase...

As what remains of 2022 dwindles into a new year, trending on the Medicare Conditional Payment front garners attention from industry stakeholders. Mounting concerns surrounding Civil Monetary Penalties associated with Section 111 Medicare Mandatory Insurer reporting (rulemaking anticipated by or before February 2023) could increase vigilance and reporting efforts. Additionally, a recent OIG audit, which coupled with procurement for various contractor positions administering the Medicare Secondary Payer program, pose changes for the last quarter of 2022 and into 2023.
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CMS published an Alert indicating it will be hosting a webinar to discuss a variety of WCMSA topics, including a summary of what's new in Medicare set-asides, and addressing questions related to the inclusion of treatments, application of state rules, re-reviews/amended reviews and more.
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