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SMART Medicare Update. Roy A. Franco Chief Legal Officer / Franco Signor LLC & Barry Dillard Manager, Guest Claims / Walt Disney World Resort. • Roy A. Franco Chief Legal Officer Franco Signor LLC

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SMART Medicare Update

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SMART Medicare Update

Roy A. Franco

Chief Legal Officer / Franco Signor LLC

&

Barry Dillard

Manager, Guest Claims / Walt Disney World Resort


  • • Roy A. Franco

  • Chief Legal Officer

  • Franco Signor LLC

  • Over the past two decades, Roy A Franco has emerged as one of the principal architects of policies and practices that define the world of Medicare Secondary Payer (MSP) compliance. The Medicare Advocacy Recovery Coalition (MARC) became the chosen vehicle for that reform effort. Founded in 2008 by Mr. Franco and other persons interested in Medicare policy, its membership comprises most sectors of the MSP-regulated community, including plaintiffs, defense attorneys, brokers, trade associations, and third part administrators. The coalition’s primary mission is to advocate for MSP on behalf of Medicare beneficiaries and companies. Its major achievement to date is the Strengthening Medicare and Repaying Taxpayers (SMART) law of 2013.

  • Drawing on his wealth of experience, in 2011 Roy Franco and Jeff Signor founded Franco Signor LLC, which specializes in Medicare compliance.


  • • Barry Dillard

  • Manager, Guest Claims

  • Walt Disney World Resort

  • Barry Dillard is the Manager of the Walt Disney World Guest Claims Department. The Guest Claims team is responsible for the handling of Guest bodily injury and property damage liability claims for the Walt Disney World Resort, Disney’s Vero Beach Resort and Disney’s Hilton Head Island Resort. Barry has 24 years of experience in the insurance industry, the last 16 years with Disney. His career began with Aetna Casualty & Surety Company as a Liability Claims Representative.


The ABC’s of SMART

  • Amended the Medicare Secondary Payer Act

  • Broad-based Support

    • MARC

    • AAJ

    • RIMS

    • DRI

    • FMI

  • Regulation is Required for Certain Aspects of Law

  • Applies to all LOB, Unless Otherwise Stated


Medicare Compliance Parts

  • Pastor “Reimbursement”

  • of “conditional payments”

  • See 42 USC 1395y(b)(2)(B)(ii)

  • Presentor “Reporting”

  • 42 USC 1395y(b)(8) and 42 CFR §411.25

  • Futureor “Protecting”

  • Medicare’s Interest

  • because “payment

    [by a primary plan] can

    reasonably be expected to be

    made” 42 USC 1395y(b)(2)(A)(ii)


SMART Key Provisions

  • Section 201: New CP Demand & Appeal Rights

  • Section 202: Sets Annual MSP Threshold

  • Section 203: Softens §111 MMSEA Penalties

  • Section 204: Prohibits Use of SSN and HICN

  • Section 205: Adds 3 Year Statue of Limitations


SMART CP Demand

  • Interim Final Rule - 42 CFR §411.39 (IFR)

  • Proposed Process:

    • Beneficiary Registers @mymedicare.gov

    • Parties notify BCRC 185 days before S/J/A

    • BCRC has 65 days to process CP, but can add 30 days

    • Download not valid, unless refreshed (before 12/31/2015) 3 days prior to S/J/A

    • Dispute process in tact

    • Still requires BCRC Demand Letter


Status on Other SMART Rules

  • Appeal Right – Request for Comment Closed 2/25/2014

  • Annual MSP Threshold – Published 2/20/2014

  • MMSEA Penalties ANPRM for Safe Harbors Closed 2/7/2014

    • OIG Work Plan 2014 to develop Rules

  • Prohibition of SSN and HICN – 1/1/2016

  • Statute of Limitations – 7/1/2013

    • Effective 7/20/2013


What SMART Did Not Address

  • Future Medicals

  • Medicare Advantage & Part D

  • Streamline Data Reporting


MSP Horizon

  • Future Medicals for Liability Claims

    • Pending Regulation – 42 CFR 411.38

  • False Claims Act and MSP Relationship

  • Medicaid Reporting


Questions, Final Comments and Contact Information

Roy Franco

roy.franco@francosignor.com

716-247-6251

Tel: 1-888-959-0692

www.francosignor.com


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