The Centers for Medicare and Medicaid Services’ (CMS) newly released 2025 Workers’ Compensation Medicare Set-Aside (WCMSA) fiscal year statistics provide fresh insight into five years of CMS activity, comparing proposed MSA amounts with CMS-recommended (or “approved”) amounts.

This year’s data reveals a notable shift: CMS MSA recommendations – the number of completed reviews where CMS issues a recommended amount – have decreased by 12% since 2023 following a prior year increase.  These insights offer valuable context for payers evaluating settlement strategies and benchmarking partner performance.

Below is a clear, easy-to-read summary of CMS’s latest data and how Tower’s results compare.

CMS MSA Recommendations are Down 12%

The agency provided five years of data covering 2021 to 2025 (CMS’s fiscal year ends on September 30), comparing proposed MSA amounts with CMS-recommended (often referred to as “approved) amounts. CMS MSA recommendations represent completed CMS reviews in which the agency issues the recommended amount needed to protect Medicare’s interest.

After a 9% increase in CMS MSA recommendations between 2022 and 2023, the 2025 data shows a 12% decrease in recommendations since 2023. The five-year average for CMS MSA recommendations is 14,611.  No reason is provided for the decline; however, the end of Zero MSA reviews this past July likely contributed to this reduction.

Average MSA Amounts Hold Steady

The average CMS MSA amount increased slightly from $85,927 in 2024 to $86,169 in 2025, which is higher than the five-year average of $84,172.

A major trend persists: the widening variance between proposed and CMS-recommended amounts. In 2025, the variance reached 24% – the highest level in the past five years – resulting in more counter-highers to CMS MSA submissions.

Prescription Medication Costs Down; Treatment Costs Stable

Prescription drug costs have steadily decreased over the past five years. The average CMS-recommended amount is now $17,501—down 16% over the past five years. Treatment costs in the MSA have remained consistent year over year but are still up 13% over the five-year span.

How Tower’s MSAs Stack Up

Tower’s CMS-approved MSAs are consistently lower than the industry average CMS-approved MSAs, which is reflected in a comparison between CMS and Tower’s metrics.

Average Approved MSA (2025):

CMS:  $86,169                                                 Tower:  $66,900

Tower’s average CMS-approved MSAs are 23% lower than the average CMS-approved MSA.

If we isolate just the prescription drug component of the MSA:

Average Rx Amount in MSA (2025):

CMS: $17,501                                                  Tower:  $11,701

Tower’s prescription drug allocations are 33% lower than the CMS average.

These metrics indicate that cost reductions are possible when payers select the CMS MSA approval process. Tower’s MSA allocation methodology and cost mitigation efforts, such as our Physician Follow-up service, effectively lower MSA allocations.

Why These Metrics Matter

CMS’s annual data release provides valuable transparency into review trends and serves as a helpful benchmark for the industry. Ultimately, partner performance drives payer outcomes. Tower’s results demonstrate that when clinical precision, compliance strategy, and operational execution come together, CMS approval can be both achievable and cost-effective.

If you have any questions, please contact Dan Anders, Chief Compliance Officer, at Daniel.anders@towermsa.com or 888.331.4941.