How Proactive and Persistent Marinda Griese Ensured CMS Compliance for CJPRMA

In insurance circles, it’s said the best claims are the ones that never happen. The same is true of non-compliance penalties. The Centers for Medicare & Medicaid Services (CMS) signaled years ago that non-compliant reporting would be subject to substantial fines beginning in October 2024.

Still, it took Marinda Griese, claims administrator at California Joint Powers Risk Management Authority (CJPRMA), to recognize the impending change’s potential scope — and to do something about it while there was still time.

“We were potentially facing over $1 million [in fines],” Griese said. “We had hundreds of files that hadn’t been reported properly.”

A high rate of reporting errors is not uncommon in this space — in fact, CMS set the acceptable rate of reporting errors to 20%.

“In workers’ comp, there’s an assumption that you’re 100% responsible for all injuries,” Griese explained. “Nothing could be further from the truth on the liability side,” where “the approach to Medicare compliance is, ‘Even if we settle something, there’s still a dispute over liability,’ so historically, it was common to push the burden to satisfy any conditional payments that Medicare may have made back onto the plaintiff.”

Still, bringing reporting into compliance was easier said than done.

“The flowchart on this process is hairy,” Griese said.

“At one point in time, we had a failure in almost every location on this flowchart … We had input failures due to staff turnover and a loss of institutional knowledge. We had system failures where the reports that would be produced were going to an employee that had retired.”

In another instance, “one of the vendors on the back end had gone through a company merge and their domain name had changed, so the data feed was no longer pointing to the right place.”

Griese took a systemic approach, first compiling a list of all problematic claims, then reviewing the steps in the process where errors were introduced, and finally setting out to track down reams of missing information. She also worked with the thirdparty RMIS vendor to correct issues with the reporting software, and with member agencies and attorneys to reformulate the process for settlement agreements.

After years of tenacious work, CJPRMA is a model of CMS compliance.

“In July of 2019, we had almost 400 query errors,” Griese said. “Today, we have none.” Her efforts have not escaped her colleagues’ attention.

“She is self-driven, dedicated, incredibly smart, incredibly curious, really technically knowledgeable at her job and enthusiastic about sharing that knowledge with peers,” said Tony Giles, CJPRMA’s general manager. &

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