CMS Releases Q&A Documents from MSA Administration & Attestation Webinar Town Halls

On February 26, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a notice and released documentation related to questions and answers (Q&A) from recent town hall webinars addressing electronic attestation enhancements in Workers' Compensation Medicare Set Aside (WCMSA) administration.

As had been previously reported, CMS held two town halls on the topic of electronic attestation submission. The first webinar, held on October 30, 2019, was dedicated to self-administration. The second webinar, held on November 6, 2019, addressed professional administrators.

There are two separate documents, aggregating Q&A from the respective webinars and both can be found in the downloads section of the WCMSA “What's New” portion of CMS's website. Specifically, the documents can be found here:

The following is a summarization of the Q&A from each document.

Q&A Summary from Self-Administration Webinar

Electronic attestation is accomplished through the Workers' Compensation Medicare Set Aside Portal (WCMSAP), which can be accessed by beneficiaries through www.mymedicare.gov.
While more efficient than paper-based submission, electronic attestation is an option for all parties and is not mandatory.
Once funds have been exhausted, attestation can be immediately submitted electronically. Providing CMS notice of temporary depletion of permanent exhaustion of funds is critical to ensuring Medicare will pay for injury-related claims otherwise covered by Medicare.
Beneficiaries are sent information on attestation submission in their WCMSA approval letter, and they can also access this in the Self-Administration Toolkit.

Q&A Summary from Professional Administration Webinar

Professional administrators will be required to register for the WCMSAP and also ensure they're associated with a particular case in order to submit electronic attestation.
If an entity already has a Corporate type WCMSAP account and they wish to submit attestations electronically, they'll also have to register separately as a Professional Administrator as this account type has functionality for electronic attestation transactions. The Corporate account type is for submitting WCMSA proposals.
The Authorized Representative (AR) role for the WCMSAP is the individual who possesses the legal authority to bind the entity to the Portal's terms of use and can be the same designated person for both Corporate and Professional Administration account types.
The AR role cannot be the same individual as the Account Manager (AM) role for the WCMSAP. The AM controls the overall administration of the WCMSAP account.
The benefits of associating a particular WCMSA case to a Professional Administration account on the WCMSAP are:
Management of the account designees' access to a case;
Visibility of the balance information;
Ability to upload account transaction files;
Access to response files.
In instances where the Professional Administrator is unable to associate a particular case with their account, final settlement documentation will need to be uploaded and validated before the case can be related to the administrator.
Functionality exists to submit bulk attestations, i.e. more than one attestation in a single file as well as on a case-by-case basis.
The accepted format for file upload transactions is a Comma Separated Value (CSV) format. The file and field layout specifications can be found in the WCMSAP User Guide.
There is no test period for electronic attestation submission. The functionality was deployed live and in production.
An opening or beginning WCMSA account balance only needs to be supplied for cases which were finalized prior to October 7, 2019.
The Benefits Coordination & Recovery Center (BCRC) can be contacted for technical assistance related to the WCMSAP and electronic attestation submission. Their telephone number is (646) 458-2255.
Corporate Account types will not have access to the attestation submission area of the WCMSAP or to its electronic submission functionality. Moreover, Professional Administration account types will have limited visibility with respect to case information.
A signed Professional Administration agreement (document type 30) is not required to be uploaded at the time of submission in ordered to associate a Professional Administrator to a WCMSA case. An unsigned Professional Administration agreement or a letter of intent on the administrator's letterhead will suffice. Either document must include the Professional Administrators name, including employee identification number (EIN) and claimant/beneficiary identifying information.

Read the full article on WorkersCompensation.com.

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