Conditional Payments / Lien Resolution
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CMS Implements Medicare Set-Aside Data Sharing for Part D Plans
by P. Czuprynski The Centers for Medicare & Medicaid Services (CMS) recently announced that beginning in February 2026, they will share data elements, including specific prescription drug information, with Part...
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A Cautionary Tale: Cabezas v. Penske Truck Leasing Co.
by B. Smith When it comes to disputes regarding the resolution of conditional liens as part of settlement, the courts will usually defer to settlement terms as their guide. This...
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Magistrate Denies Conditional Payment Reimbursement Request by MAP Plan
by P. Czuprynski In Series v. State Farm Mut. Auto. Ins. Co., 1:23 CV 22982 (July 15, 2025), the Magistrate Judge agreed that Series’ suit for conditional payment reimbursement should...
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Is Medicare Denying Payment for Treatment Under the MSP Act for Workers’ Compensation and Liability Claims?
by P. Czuprynski The Medicare Secondary Payer (MSP) Act allows Medicare to make payment and then seek reimbursement for Conditional Payments. This occurs when Medicare asks for reimbursement associated with...
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IIGF is Not a Primary Payer Under the Medicare Secondary Payer Act
by P. Czuprynski In IIGF v. Becerra[1] the United States District court for the Northern District of Illinois determined conditional payments alleged by Medicare, did not require reimbursement by IIGF...
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Administrative Procedure Act: Medicare, Medicare Advantage and Prescription Plans Must Follow its Regulations
With Chevron Deference being overturned, stakeholders facing conditional payment demands or payment denials by Medicare have a better chance of success in challenging Medicare’s decision. Federal district court review of...
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Understanding Medicare’s Three-Year Dates of Service Limitation
by P. Czuprynski The Medicare Secondary Payer Act requires reimbursement from an insurer or self-insured entity associated with a workers’ compensation, or a liability claim when there is (1) reasonable...
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CMS Issues NGHP Secondary Payer Reference Guide for Beneficiaries
by P. Czuprynski The Centers for Medicare & Medicare Services (CMS) has released version 1.0 of its Non-Group Health Plan (NGHP) Medicare Secondary Payer (MSP) Beneficiary Reference Guide pertaining to...
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Conditional Payment Case Update: Angelo Et Al v. State Farm Mutual Automobile Insurance Company Et Al
by P. Czuprynski In Angelo et al v. State Farm Mutual Automobile Insurance Company et al, No.2:19cv12165, U.S. Dist. E.D. Mich. Southern Div. (3/26/2024), the Federal District Court in Michigan...