RFI - Processing of Veteran's Administration Durable Medical Equipment, Prosthetics, Orthotics, and Supplies No-Pay Claims to Produce Medicare-Equivalent Electronic Remittance Advice Notices

THIS IS A REQUEST FOR INFORMATION ANNOUNCEMENT THIS IS NOT A REQUEST FOR PROPOSALS The Centers for Medicare & Medicaid Services (CMS) seeks information about the methods the Agency will use to process no-pay VA Durable Medical Equipment Prosthetics Orthotics and Supplies (DMEPOS) claims to produce Medicare-equivalent electronic remittance advice notices. To accomplish its goal, CMS seeks comments about the three potential implementation options that the Agency may use (see Appendix A). In addition to these three approaches, CMS will consider alternative approaches that the public identifies to best achieve the goals of the project. The information collected in this RFI may be used by the Government and included in one or more future Request for Proposals (RFP's). CMS requests responses to this RFI in the form of a white paper. White papers shall be submitted in Microsoft Word (Times New Roman, 12-point font) and are due no later than Friday, December 6, 2013. White papers shall be submitted via email only to the primary point of contact listed below. CMS will not accept hard-copy responses. In order for CMS to consider a response, the white paper shall consist of three sections and provide the information described below. CMS will not consider additional information submitted beyond these three sections. Section I. Name, mailing address, phone number, fax number, and email of designated point of contact. Section II. The name and contact information for the business or other organization whose views are represented in the paper, if that contact information differs from that provided in Section I. Section III (NO MORE THAN 10 PAGES). Complete and considered responses to each of the questions listed below for exactly two of the most preferred options OR for exactly the one most preferred option below and an alternate framework. BACKGROUND: Use of a Medicare-equivalent electronic Remittance Advice (MRA) by the VA was mandated as a result of a legal settlement between VA and USAA/Hartford in January 2003. The eMRA provides Medicare-equivalent adjudication information to secondary payers so they can accurately determine the appropriate amount of reimbursement due to the VA. Since the VA is not permitted to bill Medicare by law, a Medicare-equivalent process was developed with CMS to provide the VA with information on what Medicare would have paid, plus patients' deductible and coinsurance amounts. VA third-party billing processes incorporate this information into health care claims sent for payment to patients' secondary insurance companies (Medigap or Medicare supplementary plans). Public Law 101-508 expanded the VA authority to include recovery from third party payers for the cost of medical care provided to veterans treated for non-service connected conditions. Court rulings have determined that secondary insurance carriers are subject to these public laws and must reimburse the VA as if the care had been furnished in the private sector. In order to accomplish this, CMS and the VA have entered into an agreement whereby CMS adjudicates VA claims on a "no-pay" basis and generates Medicare equivalent medical remittance advices (MRA) for certain Part A and Part B items and services. The VA established a process with one of the Medicare Contractors to provide the VA with MRAs reflecting the deductible and coinsurance amounts due from secondary payers. Medicare secondary payers use the electronic MRA data generated to reimburse the VA for health care services provided to veterans for their non-service-connected treatment. While most services provided by the VA for Medicare eligible veterans are submitted to the designated contractor, certain items and services were excluded from the initial implementation of the MRA process. Durable Medical Equipment, prosthetics, orthotics, and supplies (DMEPOS) claims are one of several claim types currently excluded from the VA MRA process. This RFI will assist CMS in determining what technical implementation requirements would be needed to include DMEPOS claims in the VA MRA process in the future. We anticipate that including these claim types in the MRA process will require various system enhancements and additional MAC changes. QUESTIONS: This RFI seeks comment from members of the public about how CMS can best organize and assign the VA MRA project work. The feedback from this RFI may be used to develop one or more Requests for Proposal in the future that will allow CMS to administer this project. Responders should review Appendix A of this notice for information about the three proposed implementation options currently under consideration. CMS asks that each respondent address each of the following questions as it pertains to each of the two most preferred options OR for exactly the one most preferred option for organizing VA MRA project work: 1. Which of the options outlined in Appendix A do you believe best positions the VA MRA project collectively to deliver maximum value to the VA for the processing of VA DME claims? (Respondents are asked to choose and respond to two of the most preferred approaches from among the three approaches in Appendix A or its one most preferred approach and to propose one alternate method of implementation.) 2. What advantages would be realized by adopting the option(s) you articulated in your response to Question 1? Provide the pros and cons for each option (or alternative). 3. How could CMS improve each of the two options selected from Appendix A to be sure that it delivers the most impact to the VA and their goal? 4. What are some important factors for CMS to consider if the Agency were to adopt each of the chosen approaches (including any alternative approaches you suggest in your response) in organizing VA MRA project work this way? What else should CMS think about as it makes its VA MRA project framework decision? SPECIAL NOTE TO RESPONDENTS: Respondents are asked to draw their responses from objective, empirical, and actionable evidence and to cite this evidence within their responses. CMS will draw upon the quality of responses in designing the future direction of the VA MRA project. ONCE AGAIN THIS IS A REQUEST FOR INFORMATION ONLY. This RFI is issued solely for information and planning purposes; it does not constitute a Request for Proposal. This RFI does not commit the Government to contract for any supply or service. Further, CMS is not seeking proposals through this RFI and will not accept unsolicited proposals. Responders are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the interested party's expense. Not responding to this RFI does not preclude participation in any future procurement, if conducted. It is the responsibility of the potential offerors to monitor this site for additional information pertaining to this requirement. Please note that CMS will not respond to questions about the policy issues raised in this RFI or in the attached Appendix A document. CMS may or may not choose to contact individual responders. Such communications would only serve to clarify written responses further. The information provided in the RFI is subject to change and is not binding on the Government. This RFI should not be construed as a commitment or authorization to incur cost for which reimbursement would be required or sought. All submissions become Government property and will not be returned.