One number can get your attention. Six numbers can change how you look at MSA strategy. 

For years, Tower MSA Partners has been tracking outcomes across Medicare Set-Aside preparation, clinical intervention, CMS review, pharmacy exposure, conditional payment resolution, and claim closure. 

The results raise some important questions. 

• What if the first MSA isn’t necessarily the final MSA? 
• What does it take to reduce an allocation while maintaining a defensible approach to CMS? 
• How much can accurate pharmacy and clinical information change projected Medicare exposure? 
• And what happens to settlement costs when Medicare’s interests are addressed early rather than at the end of the claim? 

Those are the questions behind Tower’s new Workers’ Compensation MSP Outcomes & Regulatory Insights Report and the blog series that follows. 

Tower MSA Partners’ four-year WCMSA data shows that early clinical intervention and strong Medicare Secondary Payer compliance can lower settlement costs without sacrificing CMS defensibility. From 2022 through 2025, Tower’s average CMS-approved WCMSA remained below the national average every year. 

In 2025, Tower’s average CMS-approved Workers’ Compensation Medicare Set-Aside was $18,477 lower than the CMS national average. Across 100 annual MSA submissions, that difference represents approximately $1.85 million in projected settlement exposure. 

 But the purpose of the Outcomes Report isn’t simply to highlight a difference between Tower’s results and a national benchmark. 

The more important question is why the results look the way they do. 

This blog series will move beyond the topline results to examine the decisions behind them and what claims leaders can apply to their own programs. 

What Four Years of WCMSA Data Show 

Tower’s average CMS-approved WCMSA remained below the CMS national average in each year reviewed: 

Source: Tower MSA Partners, Workers’ Compensation MSP Outcomes & Regulatory Insights Report, Section 2.3. Differences were calculated from the reported annual averages. 

The Six Numbers at a Glance 

1. $18,477 lower: In 2025, Tower’s average CMS-approved WCMSA was $18,477 below the CMS national average. What does that difference tell us about MSA strategy—and what should claims professionals be asking before accepting an initial allocation? 

2. 33% to 64% in clinical reductions: Tower’s average annual clinical reductions fell within this range. What can current clinical information reveal that may not be apparent from the records used to prepare an initial MSA? 

3. 76% to 88% CMS alignment: Tower’s data showed substantial alignment between its reduced allocations and CMS outcomes. What does that tell us about the relationship between MSA savings and CMS defensibility? 

4. 86% with $0 opioid allocation: In 2025, 86% of Tower’s CMS-approved WCMSAs contained no projected opioid cost., How do medication histories, physician engagement, and pharmacy oversight affect future Medicare exposure? 

5. 82% of conditional payment demands reduced to $0: A Medicare conditional payment demand isn’t necessarily the final number that must be paid. What does Tower’s data tell us about the importance of investigating and resolving Medicare’s interests before settlement? 

6. $9 million to $12 million in annual savings: Tower’s data shows the scale of savings associated with Physician follow-up and pharmacy optimization. What happens when these opportunities are considered across an entire claims portfolio rather than one claim at a time? 

The results are directional benchmarks, not promises for an individual claim or portfolio. Their value is showing where process and evidence can change an outcome. 

Why These WCMSA Findings Belong Together 

The first MSA can change settlement authority. Clinical intervention can change the allocation. CMS alignment indicates whether the approach remains defensible. Pharmacy decisions affect the long-term cost of a claim. Conditional payments and $0 MSA documentation influence risk at and after settlement. 

Looking at any one metric alone misses the larger point. The final financial outcome is shaped by how well these steps work together. 

That is the purpose of this series. Each article will take one decision point from the Outcomes Report and translate it into a practical question for claims, legal, compliance, and risk leaders. 

What the Outcomes Report Blog Series Will Cover 

1. Accepting the First MSA Is Often the Costliest Decision: What Four Years of CMS Data Reveals 

When should an initial MSA be accepted, and when do outdated medications, unsupported treatment, or incomplete records justify a second look? 

2. What the CMS Alignment Index Actually Tells You About Your MSA Strategy 

How can a program challenge preventable over-allocation without sacrificing predictable, defensible CMS outcomes? 

3. Opioid Exposure in MSAs: How 86% of Tower Cases Reached $0 and What It Takes to Get There 

What clinical documentation, physician engagement, and pharmacy oversight are required to ensure an MSA reflects the treatment actually expected? 

4. CMS No Longer Reviews $0 MSAs: What That Means for Your Post-Settlement Exposure 

CMS stopped accepting or reviewing $0 WCMSA proposals effective July 17, 2025. What does that change mean for documentation, governance, and post-settlement exposure? CMS outlines the policy on its official WCMSA What’s New page. 

5. 82% of Conditional Payment Demands Reduced to $0: The Post-Settlement Number Most Programs Ignore 

What should claims teams verify before treating a conditional payment demand as an amount that must be paid? 

6. MSP as Enterprise Risk: What 2022 to 2025 Performance Data Should Change About How You Budget for Settlements 

How should MSA, CMS, pharmacy, conditional payment, and reporting outcomes inform reserves, settlement authority, loss development, and capital planning? 

What Should Claims Leaders Do Now? 

Start by comparing Tower’s findings with your own program: 

• Compare average and median approved WCMSAs with relevant CMS benchmarks. 

• Measure how often clinical intervention changes an allocation and how much it saves. 

• Track prescription drug and opioid exposure in approved WCMSAs. 

• Review proposed-to-approved variance, development letters, and conditional payment outcomes. 

• Determine whether Section 111 reporting and conditional payment work begin early enough to support settlement. 

Tower’s Medicare Set-Aside services and Medicare lien resolution connect these decisions through claim closure. 

Review the full Workers’ Compensation MSP Outcomes & Regulatory Insights Report and return to this page as each article is published. 

To compare your program with these benchmarks, submit a referral to Tower MSA Partners. 

About the Outcomes Report Data 

The report uses Tower MSA Partners’ aggregated, anonymized outcomes from WCMSAs and related MSP services between 2022 and 2025. CMS and market comparisons draw on published WCMSA statistics and related public information. The figures are intended to provide directional benchmarks and identify questions worth asking. They do not guarantee a particular reduction, approval, or settlement result for an individual claim or portfolio. 

Frequently Asked Questions About Four Years of WCMSA Data

What Is a WCMSA? 

A WCMSA allocates part of a workers’ compensation settlement for future Medicare-covered medical services related to the workers’ compensation injury, illness, or disease.