CMS will host a webinar on WCMSA Reporting on March 25

March 14, 2026

CMS will host a webinar on WCMSA reporting on March 25, 2026 at 1:00 p.m. ET to review reporting requirements, common issues, and best practices.

The Centers for Medicare and Medicaid Services will host a webinar on Workers’ Compensation Medicare Set-Aside (WCMSA) Reporting on Wednesday, March 25, 2026, at 1:00 p.m. ET.

Per CMS:

CMS will be hosting a WCMSA Reporting Webinar. The intent of the webinar is to review

the WCMSA reporting process that was implemented in April 2025, discuss some of the

issues encountered from CMS’ perspective, and review WCMSA reporting best practices.

As parties impacted by the WCMSA reporting, we also welcome anyone else involved in

the submission and administration of WCMSAs, including attorneys and Medicare

beneficiaries, to join. Please bear in mind that this Webinar is intended to broadly address

the WCMSA reporting process and questions regarding specific cases are not appropriate

for this setting.

There is no pre-registration for the webinar. Full details, including instructions on how to submit questions before the webinar, are available here and in the “What’s New” section of the CMS website.

Premier Webinar: MSP Compliance in 2026 – Regulatory Updates, Section 111 Audits & Settlement Risk

March 9, 2026

Tower MSA Partners webinar banner for “MSP Compliance in 2026, Section 111 Audits and Settlement Risk” on March 11, 2026 at 2 PM ET.

In 2025, the Medicare Secondary Payer landscape changed in meaningful ways. Section 111 WCMSA reporting became operational, and CMS discontinued formal review of $0 MSAs—fundamentally altering how payers approach settlement strategy and compliance risk.

Now in 2026, CMS is preparing to initiate its first round of Section 111 reporting audits.

What does all this mean for carriers, self-insureds, and defense counsel?

On Wednesday, March 11 at 2:00 p.m. ET, join Tower’s Chief Compliance Officer, Dan Anders, for a focused, practical discussion on how these regulatory developments are impacting workers’ compensation claims handling—and what organizations should be doing now.

You will learn:

  • The current status of Section 111 WCMSA reporting and how it is affecting settlement negotiations
  • What to expect from upcoming CMS Section 111 audits, including likely audit focus areas and compliance vulnerabilities
  • How to evaluate and document $0 MSAs in the absence of formal CMS review
  • Emerging MSA trends based on recent CMS guidance and Tower benchmarking data
  • Practical steps to mitigate civil money penalty exposure and strengthen internal controls

A Q&A session will follow the presentation. Questions may be submitted in advance during registration.

Please reserve your spot today.

Registration link: https://attendee.gotowebinar.com/register/3480677134558573406

$231K in Savings from Free Physician Follow-Up

March 4, 2026

Image of Tower MSA Partners Why Case Studies Matter series, Blog 6 $231K in Savings from Free Physicians Follow-Up.

In Tower MSA Partners’ previous post, Trimming the Fat, $175K in Savings Through MSA Optimization, we explained how MSA optimization removed $175,000 in unnecessary projected costs. In this case, a payer asked Tower to validate the treatment plan for a complex claim through physician follow-up. By engaging the treating provider, confirming current medical needs, and obtaining a physician attestation, Tower reduced the projected Medicare Set Aside (MSA) lifetime cost by $231,487 and secured CMS acceptance without development.

Identifying the Problem

The claimant’s original MSA had been created more than two years earlier. Since that time:

  • Multiple prescriptions were listed without up-to-date clinical context
  • Treatment frequency and diagnoses were not validated
  • The projected costs reflected outdated assumptions

Without direct clinical confirmation, the allocation risked inflating projected future costs and faced potential CMS scrutiny. The payer needed a defensible allocation grounded in current medical reality.

The Physician Follow-Up Solution

Tower’s clinical team initiated physician follow-up, adhering to jurisdictional rules for secure outreach. The process included:

  • Reviewing the full set of updated medical records
  • Confirming active medications, dosages, and indications
  • Discussing current therapy frequency with the treating physician
  • Validating the absence or tapering of unnecessary prescriptions

The physician confirmed that the only active prescription was Oxycodone/APAP 5/325 mg and that certain therapies were no longer needed. Armed with this clinical confirmation and a signed attestation, Tower updated the allocation.

The result was a $231,487 reduction in projected MSA costs — fully documented, fully supported, and defensible.

Collaboration and Communication

Tower MSA Partners didn’t just update numbers in a spreadsheet. Every correction was explained clearly to the claims professional and documented. The physician’s signed attestation — verifying current care and confirming that outdated items were no longer clinically necessary — was included in the CMS submission.

Because the revised MSA included accurate current clinical information and a valid attestation, CMS approved the allocation quickly and without development requests.

Why Physician Follow-Up Makes the Difference

Treatment plans evolve, medications change, and assumptions in an early allocation can become outdated. Without direct validation from the treating physician:

  • Medications may be mischaracterized
  • Frequencies may be overstated
  • Lifetime projections may overestimate future care

Physician follow-up ensures the MSA reflects actual current need, which:

  • Controls costs
  • Enhances compliance
  • Strengthens defensibility in CMS review

This case shows that physician engagement isn’t a luxury — it’s a strategic lever for both accuracy and savings.

Lessons Learned

  1. Physician engagement validates clinical need and clarifies current care.
  2. Signed attestations give CMS confidence in the accuracy of the allocation.
  3. Outdated medications and therapies can be confidently removed when confirmed to be clinically unnecessary.
  4. Defensible projections protect payers from excess costs and speed CMS review.

Results That Reflect Expertise

With targeted physician follow-up and attestation:

  • The payer realized $231,487 in reduced lifetime MSA costs
  • The updated allocation aligned with clinical reality
  • CMS approved the allocation without development requests

Tower MSA Partners delivered transparent documentation, accurate projections, and a cost-conscious, defensible settlement outcome.

FAQs

What is physician follow-up?

Physician follow-up is direct communication by Tower with the treating provider to confirm current medical treatment, active medications, and therapy needs. It ensures MSAs reflect accurate, individualized clinical information.

How does physician follow-up create savings?

By validating care with the treating physician, unnecessary treatments and medications can be removed or corrected in the lifetime projection, reducing projected future costs.

Is physician follow-up accepted by CMS?

Yes. When physician follow-up includes clear clinical documentation and, if required, a signed statement, CMS will accept updated MSAs and often approves them without development requests.

When should physician follow-up be used?

Physician follow-up can be used anytime there is open-ended medical care, outdated treatment recommendations or inconsistent or contradictory medication history.

Trimming the Fat, $175K in Savings Through MSA Optimization

February 3, 2026

Image of Tower MSA Partners Why Case Studies Matter series, Blog 5 Trimming the Fat with MSA Optimization

In Tower MSA Partners’ previous post, we showed how a MSA second opinion review helped a payer avoid ninety-eight thousand dollars in unnecessary allocation. This month, we look at a case study on how targeted MSA optimization can uncover even larger savings. Tower MSA Partners reviewed a complex claim with significant pharmacy exposure and identified an opportunity to reduce projected costs by $175,000. This case shows how structured review protocols and clinical oversight create precise and defensible MSAs.

Identifying the Problem

The claimant had a long-term injury that included frequent therapy, diagnostics, and multiple ongoing prescriptions. The initial MSA prepared by another vendor included duplicate entries, outdated treatments, and medications that had been replaced with safer and more cost-effective alternatives. Therapy frequency was also projected far beyond what the medical records supported. These inaccuracies created an inflated allocation that did not reflect current treatment patterns.

The MSA Optimization Solution

Tower MSA Partners completed a full optimization review and reconciled every projection with the latest medical records. Our clinical team verified treatment frequency, evaluated pharmacy histories, and confirmed whether each medication remained clinically appropriate. Outdated therapy, legacy prescriptions, and inaccurate frequency projections were removed or corrected. Each modification included detailed clinical reasoning and clear documentation. After optimization, the MSA decreased by $175,000 and remained fully aligned with CMS expectations. The updated allocation represented the claimant’s true medical needs without unnecessary inflation.

Collaboration and Communication

As with all Tower reviews, collaboration played a significant role. The clinical team walked the claims professional through each correction and clarified why the original allocation overstated ongoing care. Defense counsel and treating providers were updated as needed to confirm accuracy and alignment with the medical record. The optimized MSA was submitted to CMS with strong supporting documentation and was approved without development requests.

Why Oversight Makes the Difference

MSA optimization is not simply cost-cutting. It is a structured validation process that ensures every projected service is clinically necessary and supported by current documentation. Removing outdated items protects payers and claimants from unnecessary costs and strengthens the defensibility of every file. This case demonstrates how careful review drives savings.

Lessons Learned

  1. MSA optimization identifies inaccurate or outdated projections that inflate lifetime medical costs.
  2. Clinical oversight ensures medications and treatments reflect current best practice.
  3. Documentation clarity leads to predictable CMS approval.
  4. Savings come from precision. The $175,000 reduction resulted from accurate alignment with the medical record.

Results That Reflect Expertise

The optimized MSA saved the payer settlement monies and produced a compliant, defensible allocation supported by current documentation. Tower MSA Partners continues to demonstrate how clinical accuracy, alignment with CMS, and detail-oriented review generate meaningful and measurable results. Optimization is an essential tool in responsible claims management.

FAQs

What is MSA optimization

MSA optimization is a detailed clinical review that removes outdated treatments, corrects inaccurate projections, and ensures the allocation reflects current medical necessity.

How does optimization reduce allocation amounts

Optimization aligns treatment and pharmacy projections with the actual medical record, which eliminates unnecessary costs and outdated services.

When should an MSA be optimized

It is recommended for claims with long-term treatment, complex pharmacy needs, or significant changes in care since the initial projection.

Does CMS accept optimized MSAs

Yes. CMS accepts optimized MSAs when the updated allocation includes clear clinical documentation and accurate reasoning for the projected future medical.

Key Takeaways from CMS Webinar on Civil Money Penalties

January 21, 2026

Woman on a laptop reviewing Tower MSA Partners' key takeaways from CMS webinar on Civil Money Penalties

On January 15, 2026, CMS held a webinar on Civil Money Penalties (CMPs) for Non-Group Health Plan (NGHP) Section 111 Reporting. This was CMS’s final update before the first audits and penalty notices in the first quarter of 2026. Given that penalties can be substantial and impact an organization’s compliance record, understanding these requirements and deadlines is essential for all Responsible Reporting Entities (RREs).

CMS provides a full explanation of its CMP policy on its website here.

Quick Reference: Critical Dates

  • February 2026: First CMS audits begin
  • March 2026: First penalty notices expected
  • July 2026: Workers’ compensation penalty assessments begin

Audits

CMS will conduct its first audits in February 2026. The audit will randomly select 250 records from all accepted Section 111 records and non-Section 111 records obtained through CMS’s coordination of benefits and data collection methods. The 250 records will proportionally represent both NGHP and Group Health Plan (GHP) records from the prior quarter.

For the February 2026 audit, CMS will evaluate records accepted between October 11, 2025, and December 31, 2025. CMS will look forOngoing Responsibility for Meedicals (ORM) assumptions or Total Payment Obligation to the Claimant (TPOC)(TPOC) reported more than 365 days after the reportable event. This applies to ORM assumptions and TPOC dates of October 11, 2024, or later.

What Triggers Penalties

Penalties are assessed when RREs fail to report required information within mandated timeframes. Specifically, CMS looks for:

  • ORM assumptions reported more than 365 days after the reportable event
  • TPOCs reported more than 365 days after the reportable event

Special Consideration for Workers’ Compensation

As a result of the implementation of WCMSA reporting in April 2025, CMS announced that it will not assess penalties for late-reported workers’ compensation TPOCs until July 2026, with a lookback period to July 2025 instead of October 11, 2024. This grace period allows RREs to adjust to the new WCMSA reporting requirements.

Safe Harbor Protection

CMS provides a safe harbor when an RRE cannot report a TPOC because the claimant failed to provide information necessary to identify them as a Medicare beneficiary (such as their Social Security number).

Requirements to qualify for safe harbor:

  1. Make two attempts to obtain the information from both the beneficiary and their attorney by mail or email
  2. Make one additional attempt to either the beneficiary or their attorney by phone, mail, or email
  3. Document all attempts with dates, methods, and responses
  4. If either the claimant or their attorney provides a written refusal to cooperate, no further attempts are needed

Important notes:

  • Federal law does not prohibit the RRE from contacting the claimant directly, even when the claimant is represented by an attorney
  • Contact must be made with both the attorney and the claimant until one of them either provides the information or provides a written refusal

All documentation of these attempts must be retained and provided to CMS if a penalty arises.

Acceptable documentation includes copies of emails, certified mail receipts, phone logs with dates and summaries of conversations, and written refusals.

Penalty Notice Process

Informal Notice

CMS expects the first penalty notices to be sent in March 2026. These informal notices will be mailed to the RRE’s Authorized Representative, with a copy to the Account Manager. Importantly, the reporting agent (such as Tower or other third-party administrators) will not be copied on the notice.

Action required:

Given the importance of receiving these notices, RREs should immediately verify that their Profile Report contains up-to-date contact information for both the Authorized Representative and Account Manager.

Upon receipt of an informal notice, the RRE has 30 days to provide a response, including a reasonable explanation as to why either the TPOC report or the ORM assumption report was untimely.

Possible defenses include:

  • The claimant refused to provide their Social Security number (safe harbor applies)
  • Delayed acceptance of a claim due to litigation or investigation
  • Administrative errors with documented corrective measures
  • Technical issues with CMS submission systems

If CMS accepts the explanation, there will be no further action.

WC Reporting Penalties

As a result of the implementation of WCMSA reporting in April 2025, CMS announced that it will not assess penalties for late-reported workers’ compensation TPOCs until July 2026, with a lookback period to July 2025 instead of October 11, 2024.

Formal Notice

If CMS does not accept the explanation or there is no response to their informal notice, a formal notice, called a Notice of Proposed Determination to Impose a Civil Money Penalty, will be mailed to the Authorized Representative and copied to the Account Manager for the RRE.

Appeals Process

The appeals process provides multiple levels of review:

Level 1 – Administrative Law Judge (ALJ): The RRE has 60 days from receipt of the Proposed Determination to appeal to an ALJ.

Level 2 – Departmental Appeals Board: If the ALJ’s decision is unfavorable, the RRE has 30 days to file an appeal with the Departmental Appeals Board Appellate Division.

Level 3 – Federal Court: If the Departmental Appeals Board appeal results in an unfavorable decision, the RRE has 60 days to petition for judicial review in federal court.

Payment

Once the appeals process has concluded, or if no appeal is filed, a Notice of Final Determination will be sent to the RRE. The RRE has 60 days from receipt to make payment electronically through pay.gov.

Best Practices and Final Thoughts

The timeliness and accuracy of Section 111 reporting will mitigate and, ideally, eliminate any possibility of a penalty. To protect your organization:

Proactive measures:

  • Implement robust processes to capture Medicare beneficiary information at first contact
  • Establish clear procedures for the three-attempt safe harbor requirement with documentation templates
  • Maintain detailed records of all attempts to obtain beneficiary information
  • Review and update your CMS Profile Report contact information immediately
  • Develop internal timelines that build in buffer time before the 365-day reporting deadline

If you receive a penalty notice:

  • Respond immediately within the 30-day window
  • Coordinate with your Section 111 reporting agent, if applicable, to identify all possible defenses
  • Gather all documentation supporting your explanation

Please contact Tower’s Chief Compliance Officer, Dan Anders, at daniel.anders@towermsa.com with any questions.

A $98K Mistake Avoided, The Value of Second Opinion MSA Reviews

January 12, 2026

Image of Tower MSA Partners Why Case Studies Matter series, Blog 4 A $98K Mistake Avoided with a Second Opinion MSA Review

In Tower MSA Partners’ previous post, we explained how Physician Peer Review generated more than one million dollars in savings while strengthening CMS compliance. This month, we shift focus to the importance of accuracy. Tower MSA Partners was asked to review a Medicare Set Aside allocation prepared by another company, and the findings revealed a significant error that would have cost the payer ninety eight thousand dollars. This case illustrates why a second opinion is a valuable safeguard in every MSA strategy.

Identifying the Problem

The claim involved ongoing treatment, therapy, and pharmacy exposure. The original MSA prepared by another vendor appeared complete, and the projected costs seemed typical for this type of injury. Once Tower MSA Partners reviewed the file, the clinical team found inconsistencies that required deeper investigation. Several treatment projections did not align with the documented medical record. The file also listed duplicate items and outdated medications that had already been removed from the claimant’s regimen. The largest issue involved a discontinued high-cost prescription that remained in the allocation. This error inflated the MSA by nearly one hundred thousand dollars and created unnecessary CMS risk. If submitted as written, the payer would have funded care that no longer existed and faced questions about clinical justification.

The Second Opinion Solution

Tower MSA Partners completed a complete second opinion MSA review. Analysts verified each treatment recommendation and cross-referenced records with the most current documentation. Pharmacy history was compared to recent physician notes to ensure accuracy. The discontinued medication was the key discrepancy. The treating physician had replaced it with a lower cost, safer alternative, and the original reviewer failed to revise the allocation. Tower updated the MSA to reflect the correct medication plan and documented the clinical reasoning in clear, concise terms. With the correction in place, the projected cost of the MSA decreased by ninety-eight thousand dollars while maintaining complete alignment with CMS guidance.

Collaboration and Communication

Tower MSA Partners emphasizes transparency in every step of the review. The clinical team explained each correction and helped the claims professional understand why the original allocation was inaccurate. This clarity supported confident decision making and prepared the file for CMS submission. Tower also communicated updates with the defense attorney and treating provider, so all parties understood the medical basis for the revisions. When submitted to CMS, the revised MSA was approved without development requests. Accurate documentation and clinical alignment created a predictable approval process.

Why Oversight Makes the Difference

Accuracy is essential in Medicare Set Aside management. Even a small oversight can inflate lifetime medical projections and expose the payer to avoidable costs. A second opinion MSA review provides an essential layer of validation that confirms medical necessity, eliminates outdated information, and protects the overall integrity of the claim. This case demonstrates that clinical oversight and cost savings work together. Correcting the allocation not only protected the payer from unnecessary spending but also ensured that the file met CMS expectations with confidence.

Lessons Learned

  1. A second opinion review prevents costly mistakes and confirms accuracy before submission.
  2. Outdated information leads to inflated costs, especially in pharmacy heavy claims.
  3. Strong clinical documentation makes CMS approval predictable and efficient.
  4. Precision drives savings. The ninety-eight-thousand-dollar reduction resulted from careful review and experienced analysis.

Results That Reflect Expertise

By requesting a second opinion, the payer avoided a ninety-eight thousand-dollar over allocation and gained a compliant, defensible Medicare Set Aside. The corrected review reflected actual medical necessity and prevented unnecessary long-term funding. This case highlights Tower MSA Partners’ continued commitment to accuracy, clinical alignment, and cost containment. A second opinion review is more than a quality check. It is an essential safeguard for payers, claimants, and settlements.

FAQs

What is a second opinion MSA review?
A second opinion review evaluates an MSA prepared by another company to confirm accuracy, clinical validity, and compliance with CMS guidelines.

How do second opinions create savings?
They uncover outdated treatments, discontinued prescriptions, and projection errors that inflate total costs.

When should a second opinion be considered?
Any claim with complex medical history, high pharmacy exposure, or uncertainty about the accuracy of an existing MSA benefits from a second opinion.

What is a second opinion MSA review?

A second opinion review evaluates an MSA prepared by another company to confirm accuracy, clinical validity, and compliance with CMS guidelines.

How do second opinions create savings?

They uncover outdated treatments, discontinued prescriptions, and projection errors that inflate total costs.

When should a second opinion be considered?

Any claim with complex medical history, high pharmacy exposure, or uncertainty about the accuracy of an existing MSA benefits from a second opinion.

 

Happy Holidays!

December 22, 2025

Happy Holidays from Tower MSA Partners!

As we celebrate the holiday season, all of us at Tower MSA Partners want to take a moment to say thank you.

We are deeply grateful for the trust you place in us. Your collaboration, confidence, and shared commitment to Medicare Secondary Payer excellence make our work meaningful, and we value the opportunity to support you each day.

We hope this time offers moments of rest, reflection, and connection with those who matter most. We look forward to continuing our work together in the year ahead.

Warmest wishes for a joyful holiday season, Merry Christmas and a healthy, successful New Year.

With gratitude,
Tower MSA Partners

CMS 2025 WCMSA Metrics Show Ongoing Decline in WCMSA Reviews and Rx Costs

December 15, 2025

CMS Metrics Show Ongoing Decline in WCMSA Reviews & Rx

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.

CMS to Host Webinar on CMPs on January 15

December 10, 2025

CMS to Host Webinar on CMPs on January 15

The Centers for Medicare and Medicaid Services (CMS) will host a webinar regarding Civil Money Penalties for NGHP Responsible Reporting Entities (RREs) on Thursday, January 15, 2026, at 2:00 p.m. ET. Per CMS:

The presentation by CMS will include reminders about the Final Rule and auditing process, anticipated correspondence, and a question-and-answer session.

Note, this is a different CMS webinar topic than the October 1, 2025, session on WCMSA reporting that was scheduled and canceled due to the government shutdown.

There is no pre-registration for the webinar. Full details, including instructions on submitting questions before the webinar, can be found here and in the “What’s New” section of the CMS website.

 

$1 Million Saved with Physician Peer Review

December 4, 2025

Image of Tower MSA Partners Why Case Studies Matter series: Blog 3 $1 Million Saved with Physician Peer Review

In Tower MSA Partners’ previous post, we explored How Pre-MSA Triage Prevented $774k In Unnecessary Costs” by diagnosing issues before submission. This month, we move from prevention to precision. Through a comprehensive Physician Peer Review, Tower MSA Partners helped a client reduce projected MSA costs by more than $1 million, reinforcing how clinical oversight transforms both financial and compliance outcomes.

Identifying the Problem

The claim involved a long-term pain management case where the claimant had been prescribed multiple overlapping therapies and high-cost medications for years. On paper, everything appeared compliant, but Tower’s experienced analysts recognized red flags. The medications had not been re-evaluated for clinical necessity, and several treatments were duplicative or no longer consistent with current medical standards.

Left unchecked, the proposed MSA would have locked the payer into unnecessary costs for the claimant’s lifetime medical care. Beyond the financial impact, the payer also faced potential CMS scrutiny for including treatments without supporting clinical documentation. This is where Tower MSA Partners’ layered review process stepped in.

The Physician Peer Review Solution

Tower’s team initiated an independent Physician Peer Review, assigning the case to a licensed physician with expertise in pain management. The reviewer conducted a full analysis of the medical history, treatment progress, and prescription patterns. This deep clinical evaluation uncovered that several medications could be tapered or replaced with safer and lower-cost alternatives.

For example, the claimant was taking a combination of opioid medications that exceeded current best practice guidelines. The reviewing physician documented a detailed rationale for modification, providing evidence-based recommendations that were not only medically sound but also compliant with CMS expectations.

Once incorporated into the revised MSA, these adjustments reduced projected costs by more than $1 million while maintaining patient safety and treatment continuity.

Collaboration and Communication

One of Tower MSA Partners’ key strengths lies in its ability to bridge communication between medical reviewers, claims professionals, and legal teams. Rather than simply returning a report, Tower’s clinical experts walked the client through each recommendation, explaining how and why changes were appropriate. This transparency ensured that the payer, the defense attorney, and the treating physician were aligned before submission.

The final MSA reflected current medical necessity and included detailed documentation supporting each change. When presented to CMS, the submission received prompt approval with no development requests — a testament to the thoroughness of Tower’s process.

Why Oversight Makes the Difference

In MSA management, accuracy is everything. A single unchecked treatment plan can inflate costs by hundreds of thousands of dollars. Physician peer review adds a layer of expert validation that standard file reviews simply cannot provide. By ensuring that each projected medical service is both necessary and properly justified, Tower protects clients from avoidable financial and compliance risks.

This case demonstrates the tangible value of pairing clinical and administrative expertise. It also reinforces a key truth in the MSA industry: compliance and savings are not competing goals. When handled correctly, one strengthens the other.

Lessons Learned

  1. Medical oversight pays off. Involving a physician reviewer early or mid-process can uncover inefficiencies that purely administrative reviews miss.
  2. Documentation drives approval. Every modification included detailed clinical support, making CMS approval faster and more predictable.
  3. Collaboration builds trust. Transparent communication between Tower, the client, and treating providers eliminated resistance and ensured everyone understood the reasoning behind the changes.
  4. Savings reflect strategy. The $1 million reduction was not luck,  it was the result of structured review protocols, experienced medical oversight, and Tower’s culture of precision.

Results That Reflect Expertise

Beyond the financial win, this case underscored Tower MSA Partners’ reputation for pairing clinical insight with regulatory mastery. The client achieved measurable ROI, CMS compliance, and peace of mind knowing that future medical allocations were realistic, defensible, and supported by clinical data.

Each peer review conducted by Tower is more than a medical check — it is a safeguard for payers, claimants, and settlements. This case serves as another example of how Tower delivers consistent, evidence-based results that protect both cost and care quality.

FAQs

What is a Physician Peer Review in MSA?

It is an independent medical evaluation that confirms treatment plans and medications in an MSA are clinically justified and aligned with CMS guidelines.

How does Peer Review reduce MSA costs?

By identifying unnecessary or outdated treatments and offering safer, evidence-based alternatives, peer review reduces total medical cost projections without compromising care.

Does CMS recognize Peer Reviews?

It’s important to combine the peer review with clinical oversight to document the changes to the treatment plan and medication regimen, which CMS will recognize.

When should an MSA include a Peer Review?

Any time a claim involves long-term treatment or high medication costs, a peer review should be performed before submission.