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Mandatory Insurer Reporting (MIR) became law in 2007. It became mandatory in workers' compensation claims in 2010, and in liability claims in 2011. Since then, Responsible Reporting Entities (RREs) now must provide Medicare with specific data outlining the details of any claim in which the claimant is a current Medicare beneficiary. Cattie & Gonzalez provides the following MIR services:
Cattie & Gonzalez incorporates MIR components in every one of the services we provide. In other words, if hired to calculate an MSA Allocation or draft an MSA Legal Opinion, we will reach out to the client’s reporting agent and obtain all relevant information regarding the correct type of claim (LIA, NF, or WC), ongoing responsibility for medical (ORM), medical codes related to the claim (ICD), and total payment obligation to claimant (TPOC). If we are hired to work on Medicare conditional payments, we will audit for accuracy and consistency of 1) ORM dates and termination of ORM, 2) ICD reported codes, and 3) TPOC dates and amounts to help protect clients from unnecessary exposure to potential Civil Monetary Penalties.
Cattie & Gonzalez specializes in Direct Data Entry (DDE) mandatory reporting services. For clients with less than 500 reportable claims per year, we provide RREs the ability to directly report all necessary and required components of liability, no-fault, and workers compensation claims as delineated in the latest CMS NGHP MIR User Guide, so as to be compliant with the mandates of MIR and not liable for potential $1,000 per day per file
civil money penalties.
We will query each claimant for current Medicare beneficiary status, including Medicare Advantage and Prescription Plan eligibility on a monthly basis. If the claimant is Medicare eligible, we will then and report ORM assumption date/termination date if applicable, ICD-10 related codes, and TPOC date(s) and amount(s) in order to help protect clients from unnecessary exposure to potential $1,000 per day per file civil money penalties.
One of the most significant challenges for any size RRE is to truly understand and comprehend their reporting agent's MIR compliance, the status of its current MIR data, the accuracy of its MIR data points, and the likelihood of successful transmission of those to CMS. Through our MIR Audit Services, Cattie & Gonzalez provides its clients the opportunity to review, analyze, test, and determine the accuracy of a client's own internal or reporting agent's process, whether the right MIR information is being collected, whether that data is accurate, whether the data points are being communicated timely to CMS, and whether such information is being used as intended by CMS throughout the conditional payments resolution process and set aside allocation review process.
Perhaps the most frustrating component of MIR for any size RRE, whether using a reporting agent or reporting the data on its own, is the determination of whether the data points reported to CMS on a quarterly basis are correct. This has now taken on significant importance given the fact that up to $1,000 per day per file civil money penalties may apply to incorrect data provided to CMS. Cattie & Gonzalez will review your claim’s accident/incident information to provide a legal opinion indicating the correct DOA/DOI and an accurate description of the accident/incident. We will also review your medical records to provide our legal opinion on the correct ICD-10 related to the claim and an accurate description of the medical conditions treated as a direct result of the claim to be reported as ORM. We will also review legal pleadings and settlement documentation to ascertain and provide our legal opinion on the correct date of settlement and accurate amount to be11 reported as TPOC.