CMS Holds Webinar on Electronic Attestation for Professional Administration
On November 6, 2019, the Centers for Medicare & Medicaid Services (CMS) held a webinar entitled, “Workers’ Compensation Attestation Enhancement Webinar for Corporate Users & Professional Administrators.” This webinar focused on topics related to a professional administrator’s use and submission of electronic attestation information via the Workers’ Compensation Medicare Set Aside Portal (WCMSAP).
CMS indicated the purpose of the enhancements are to allow for Professional Administrators to:
- Upload account transaction files for WCMSAs they administer
- Download response files for each submitted file
- Reconcile WCMSA balances with the current balance stored on the WCMSAP
- Eliminate the need to use mail (although mailing will still be an available option)
In order for a professional administrator to avail themselves to the functionality of electronic attestation submission, they’ll be required to register for the WCMSAP as a “Professional Administrator” “account type.” This will allow the professional administrator to be linked to the WCMSA submission case through the portal.
Professional administrators will have visibility of WCMSA cases that they administer, including viewing the current WCMSA account balance that is reflected with CMS. This will allow for professional administrators to better reconcile and resolve potential discrepancies.
Functionality & Process of Electronic Attestation Submission
CMS clarified there will be functionality for a “bulk file” upload so professional administrators can electronically transmit information with multiple cases included in a single file. During the webinar, CMS referenced and walked-through the submission File Layouts, Response File Layouts and associated Error Codes found in Appendix B the updated WCMSAP User Guide. These files will contain the associated attestation data submitted and returned on a particular case, along with potential errors (on the Repose File) that may have caused a file to not process.
When a file is uploaded there will be an indication showing that it was successfully submitted, and the date and time of the upload will display. In the “Download Response File” section, response files will be available for download up to one year if the number of files does not exceed 500. CMS recommended that if a professional administrator wanted to keep the files for a longer period of time that the should save an electronic copy internally for future reference.
Of note, a bulk file upload utilizing the File Layouts with the many detailed administration data points – including ICD, CPT codes and treatment information - will not be available in self-administration electronic submission situations. This process will only be available to professional administrators.
Updated Functions for Submitters
For WCMSA submitters utilizing the portal, there is now an additional step with respect to identifying the “Administration Type” during the submission process. CMS’s John Jenkins advised if the parties are intending to have the MSA professionally administered that the professional administration company should be designated at this time. Mr. Jenkins indicated associating the professional administrator with a case at the time of submission makes it much simpler and smoother when the matter resolves and is ready to be professionally administered. While a document is required to move forward in the submission process when professional administration is selected, an unsigned copy of a professional administration agreement is acceptable. A signed agreement can subsequently be uploaded in the portal.
A Big Step Forward for Professional Administration
Ametros, as the industry-leader in professional administration, has been at the forefront of advocating for the submission of electronic attestation information. We applaud CMS for making these enhancements and to allow for a new process that will provide so many benefits to parties’ post-settlement. As we’ve previously indicated, electronic reporting will allow for better coordination of benefits after the settlement, more actionable and accurate data, and the ability for both CMS and professional administrators to track and forecast the expenses and spend on an MSA account.
These major enhancements to the WCMSA program evidence that CMS is continuing to pay much more attention to and place a greater emphasis on post-settlement administration. As stated in CMS’ WCMSA Reference Guide (Version 3.0), within Sec. 17.1, CMS continues to “highly recommend” professional administration as it did in prior versions, regardless of the scenario, by indicating that: “[a]lthough beneficiaries may act as their own administrators, it is highly recommended that settlement recipients consider the use of a professional administrator for their funds.” Professional administration provides the highest levels of protection for all settling parties and ensures proper care and coordination of benefits post-settlement.
Should you have any questions about electronic attestation submission or this webinar, please do not hesitate to contact us.