How Healthy Are Your Tax Identification Number (TIN) Reference Files?

by P. Czuprynski

Responsible Reporting Entities (RREs) need to report Ongoing Responsibility for Medical (ORM) or Total Payment of Obligation to Claimant (TPOC) associated with a workers’ compensation or liability claim.

When RREs (or their vendors) report these events, a TIN Reference File is associated with the claims. This file matches the claims submitted with the RREs Tax ID, contact, and other specific information. A feature of the TIN Reference File is a data field called Office Code. This field allows Third Party Administrators (TPAs), or other vendors, to divert mail to their location for the set of claims that the TPA is reporting on behalf of the RRE.

At its basic level, this option makes a lot of sense as carriers/self-insureds often use TPAs to manage claims, including conditional payments that may result from the reporting. Additionally, if there is a question from Medicare regarding whether ORM termination is needed, Medicare will know to send the request to the TPA.

The Office Code option is NOT the same as listing an entity as a Recovery Agent. Recovery Agents have their own data set in the TIN Reference File and are only associated with the set of claims submitted with that particular TIN Reference File.

This means that an incorrect TIN Reference File could result in conditional payment letters going to the wrong address, or in a Recovery Agent not being copied on certain conditional payment correspondence. Moreover, an invalid address could lead to a demand going unanswered and being turned over to treasury for collection.

Invalid TIN record or office code (TN99[1]) was the most common Section 111 Reporting error identified by Medicare from July 1 – December 15, 2023. Because of the importance of the TIN Reference File and potential high risk for error, RREs should consider identifying the office codes associated with their company and, if necessary, confirming that TPAs are using them accurately.

If you have questions about TIN Reference Files or how IMPAXX can help evaluate them, coordinate any changes, and dispute any resulting conditional payments on your behalf, please contact us at [email protected].


[1] TN99 – No matching, valid TIN Reference File Detail Record was found for the TIN/Office Code combination on the Claim Input File Detail Record.