Automation has its place, but it can’t replace people in MSP compliance

October 3, 2022

Technology isn’t everything.  It may seem hard to believe that I have said this because most of my career was steeped in technology.

In my past life, I developed automation systems for pharmacies and workers’ comp pharmacy benefit management (PBM) models. Rules-based adjudication platform allowed for automatic Rx fills for many prescriptions, but also supported trigger-based escalation for the outliers to request authorization or have an expert take a closer look. The time saved and convenience provided were astounding.

When we started Tower, Kristine Dudley and I automated much of the paper-intensive world of Medicare Set-Asides, and also integrated the 3 major components of Medicare Secondary Payer compliance, Section 111 Mandatory Insurer Reporting, Conditional Payments and Medicare Set Asides, into a single platform. I believe we were the first to do that.

Our platform, Tower’s MSP Automation Suite, was built based on state workers’ compensation statutes overlayed with WCMSA guidance, metrics-based KPI tracking and intervention / escalation triggers that supported MSP best practices.  By seamlessly integrating Section 111 reporting, conditional payment resolution, and MSA preparation into a single, all-encompassing system, our MSP Automation Suite ensures that nothing drops through the cracks, no field goes unpopulated, problem cases can be identified, and deadlines are met.

Tower’s MSP Automation Suite captures, stores and manages all data points, integrates with ANY claims system, enables clients’ business rules to be overlaid onto ours, and gives our clients end-to-end visibility into Medicare and claim information.  Our system also leverages embedded triggers to escalate medical and pharmacy issues, prompting a review for intervention. In short, Tower’s MSP Automation Suite leverages the best of automation until technology intersects with the need for expertise.  This allows our team to manage, track and drive MSP compliance from the moment a Medicare beneficiary is identified through the claim’s closure.

Do we love automation?  You bet we do.

But we realize automation can’t do everything. MSP compliance has always – and will always – require a high degree of consultative expertise. You can’t just capture and populate data fields, and automatically “pop” out an MSA that supports aggressive cost mitigation that is both CMS-approvable and facilitates settlement.

While many workers’ compensation claims move through the system seamlessly, others are “messy”.  Body parts may be denied, additional claims may exist, co-morbid conditions may complicate treatment, surgeries, medical treatment and medications may be prescribed inappropriately or ICD10 codes may be too general or inconsistent with the treatment being paid by the carrier.  These are just a subset of the rules-based triggers built into our system so that claims warranting attention are automatically escalated to a human expert to dig through files, examine causation questions, and probe open-ended medical care and contradictory medical records.

Clients need their calls, emails and questions answered by real people, and quickly. Complex conditional payment matters call for conversations … with a knowledgeable partner who shares your goals.

Our automated system escalates medical and pharmacy issues, but then you need a professional with specialized knowledge and experience to recommend the best intervention.  And to implement it.

One of our most effective interventions created by Tower is our Physician Follow-up. Guess what? This is performed by people, people who have the patience and commitment to keep trying to talk to the provider. If you’ve tried to call and talk to your own doctor lately, you know what a challenge this can be.

These professionals have the knowledge and soft skills needed to delicately point out vague notes and open-ended recommendations in medical records. And they must be able to persuade the provider to clarify their treatment and prescriptions. Drafting a jurisdiction-specific statement for the provider to sign requires yet another human skill set.

If I had to name the one aspect that drives Tower’s success, I’d have to say service.  Our technology enables us to respond quickly, anticipate issues, and proactively address them, but it’s the people, their attitudes, and their expertise our clients value the most. 

The common thread in our client testimonies are service and partnership. Clients are “very impressed with [Tower’s] level of communication and availability to help answer questions,” and they say, “they truly listen; listen to understand and not just to respond.”

Perhaps this person sums things best: “They have advanced technology and certified specialists to ensure no stone is unturned.”

Insurance carriers, self-insureds and TPAs are dealing with shortfalls in staffing.  There’s more pressure on the experienced adjusters, and the new hires need all kinds of support to get up to speed on MSP matters.  Tower MSA Partners is here to help. That’s what the Partners part of our name means.

We are proud of our technology, and we recognize when to leverage it and when automation must give way to consultative expertise. There is a need for partnership with real people who care about your claim closure and settlement and can ensure that happens with the right balance of care, cost and compliance.

If you have any questions or just want to talk about partnership opportunities, the expertise of our people, or our technological capabilities contact me at rita.wilson@towermsa.com.

Tower MSA Partners Receives 2022 SOC 2 Type II Attestation

May 3, 2022

logo for AICPA. which conducts the SOC 2 Type II Audit

Independent Audit Verifies Tower MSA Partners’ Internal Controls and Processes

Delray Beach, FL – Tower MSA Partners, a Medicare Secondary Payer compliance services company, today announced that it has completed its annual SOC 2 Type II audit, performed by KirkpatrickPrice. This attestation provides evidence that Tower has a strong commitment to security and to delivering high-quality services to its clients by demonstrating that they have the necessary internal controls and processes in place.

A SOC 2 audit provides an independent, third-party validation that a service organization’s information security practices meet industry standards stipulated by the AICPA. During the audit, a service organization’s non-financial reporting controls as they relate to security, availability, processing integrity, confidentiality, and privacy of a system are reviewed, examined and reported on. The SOC 2 report delivered by KirkpatrickPrice verifies the suitability of the design and operating effectiveness of Tower MSA Partners’s controls to consistently meet the standards for these criteria throughout the full audit period.

“The SOC 2 audit is based on the Trust Services Criteria,” said Joseph Kirkpatrick, President of KirkpatrickPrice. “Tower delivers trust-based services to their clients, and by communicating the results of this audit, their clients can be assured of their reliance on Tower’s controls.”

“It’s an honor to again earn an unqualified 2022 SOC 2 Type II outcome” said Wilson. “It’s an attestation that Tower’s systems, policies and procedures meet the trust services criteria of security, availability, processing integrity, confidentiality, and privacy.”

What does this mean for you?

  1. Peace of mind.
    If you partner with Tower, you can be assured that

    • Our human processes and our highly automated system– have been validated by third-party auditors after a stringent analysis.
    • Your data is transferred safely, used appropriately, stored securely, and is accessible for the required amount of time.
    • You can partner with a best-in-class MSP services provider and superior technology.
  2. Cybersecurity assurance. Auditors recognized Tower’s commitment to keep up with cyber threats, patching, monitoring methods and cybersecurity technology. They saw that we monitor all internal systems for patching cadence and antivirus/antimalware activity, we regularly train staff on how to avoid the latest scams, and we execute multi-factor authentication and password changes to prevent breaches. In addition, we partner with reliable and well-respected cloud storage, monitoring, and security companies.

While the complete report is confidential and proprietary, a redacted synopsis of the report, SOC 3, can be downloaded here. I’m happy to answer questions and discuss the value of partnering with Tower for your MSP compliance and MSA needs. Please contact me at Rita.Wilson@TowerMSA.com to arrange for a conversation.

Tower MSA Partners 10-Year Anniversary and 10 Distinguishing Achievements

September 21, 2021

Tower MSA Anniversary Logo

We’re celebrating the Tower MSA Partners 10-year anniversary this year! To commemorate this landmark year for our business, we’ve compiled 10 distinguishing achievements over the decade that we’re proud of and that we think differentiate us from others in our field.

  1. Our single focus. We don’t try to be all things to all people, we focus on doing one thing extremely well. Everything we do is geared toward smooth settlements with 100% compliance with Medicare, cost-effective Medicare Set-Asides (MSAs) and partnering with clients on outcomes. Focusing our business model on Medicare Secondary (MSP) compliance and MSAs enabled Tower to develop technology specifically for this industry, hone our expertise, and become the industry’s “go-to” experts in these areas.
  2. We are “Measurably Better.” Our tag line “Measurably Better” is not just a clever use of words, it’s the backbone of all that we do. We run our business on metrics, tracking and measuring everything that matters in MSP compliance and MSAs.  Metrics drive Tower’s internal efficiency improvements and technology enhancements.  It’s how we help our clients improve their MSP compliance and MSA programs and how we prove we—and our clients’ programs–are measurably better.
  3. Our commitment to continuous improvement. We’ve aggregated 5 years of CMS response data to identify CMS performance metrics that matter to our clients and we track these monthly. And we continue to monitor every response CMS has to every one of our MSA submissions. When we think CMS is wrong, we challenge by proactively pushing the envelope to get the best possible results for our clients. Otherwise, we use the response data to reverse engineer internal processes to improve our MSA work product.
  4. Everything we do is technology driven. We built our own technology from the beginning specifically to address this industry and our clients’ needs. Our technology is based on the best practices of MSP compliance and MSA preparation. There’s no patchwork of disparate systems or data in silos that needs to be extracted, just a seamless, integrated system that drives all compliance and MSA processes.  Tower’s Section 111 Management Dashboard gives clients full visibility into their claims from a global level all the way down into the details of an individual claim. Technology Drives Better Medicare Secondary Payer Compliance.
  5. Our commitment to cybersecurity. With a clear understanding of the importance of our systems, software, and data to Tower’s business functions and a keen awareness of the reality of cyberthreats in today’s digital environment, Tower has taken major steps to develop its enterprise-wide security infrastructure to guard against, detect and mitigate cyberattacks. This includes partnering with a data security firm that monitors data traffic 24/7, responds to threats in real time, provides direction to keep client data secure, and gives Tower unlimited access to incident response resources if attacks occur. monitoring data traffic 24/7, responding to threats in real time and   Building a Better Tower – Cybersecurity.
  6. We’ve earned external third-party validation.  Tower MSA Partners completed its SOC 2 Type II audit, providing external third-party validation that a service organization’s information security practices meet industry standards stipulated by the AICPA. Tower MSA Partners Completes SOC 2 Type II Audit.
  7. We are independent and women owned. We are wholly owned by our founders, CEO, Rita Wilson and COO, Kristine Dudley, Tower is a certified Women’s Business Enterprise (WBENC). Celebrating Tower’s History as a Women-Owned Business.
  8. Our stellar team. You can meet our outstanding leadership team, the top experts in the business. The passion and dedication of our certified MSA specialists, nurses, Quality Assurance team, and compliance staff are incredible. Their efforts enable Tower to manage by our metrics and drive results. Many have been with us since the beginning and became managers as they gained knowledge and skills. We are a cohesive team at all levels. But for our real secret sauce, learn more about how Tower Nurses Make a Difference.
  9. We get results. Our systematic, aggressive approach to identifying and reducing unnecessary cost-drivers on MSAs saves clients hundreds of thousands of dollars on MSAs. Our certified specialists know what to look for and our technology, metrics, and processes give them all the tools they need to find every cent of savings. Because we record CMS response to every MSA, we can confidently produce MSAs that balance care, cost, and compliance.  Check out our case histories, request others or ask for a free second opinion on an MSA.
  10. Our clients love us. Hers’s an excerpt from one: “Second to None”….When I hear this idiom, I immediately think of Tower MSA Partners… While there are many MSA vendors, only one company, Tower MSA Partners, is “Second to None.” Tower serves their partners by guiding and directing from start to finish. They have advanced technology and certified specialists to ensure no stone is unturned. Regardless of the complexity or how fast you need help, Tower leads and delivers results that are always accurate and timely, serving you like family. Bryan Conner, Manager, Workers’ Compensation, American Airlines. See our Testimonial page to read more from Bryan and our other clients.

We are honored to serve clients like American Airlines, Acuity Insurance, Aramark, BETA Healthcare Group, CPC Logistics, Montana State Fund, Tyson Foods, and others, some who prefer not to have their names published.  From the beginning, Tower sought partnership relationships with clients; we put “partners” in our name.

On our 10th Anniversary, I want to thank our client partners who have trusted us with their MSP and MSA needs, our employees who are just stellar, and our executive leadership team who are the best of the best.  We look forward to continuing to serve our existing clients, help new ones achieve their goals, and continue our close partnerships.

 

Tower MSA Partners Ready to Steer Clients Through Pending Section 111 Civil Money Penalties

April 1, 2021

View from Dashboard over highway to illustrate Section 111 Civil Money Post

Last year the Centers for Medicare and Medicaid Services (CMS) proposed regulations on Section 111 civil money penalties (CMPs). See Tower MSA Partners’ detailed prior post, CMS issues Proposed Rule for Mandatory Insurer Reporting Penalties related to inaccurate or untimely Section 111 Medicare Mandatory Insurer Reporting. Some of these are shocking – up to $1,000 per day per claimant in some cases.  Tower and others in the Medicare Secondary Payer (MSP) industry collaborated on comments to CMS’s proposal.

Then, Tower went well beyond simply responding to CMS.  We took proactive measures to prepare our clients for the eventual penalties. We educated clients with a webinar focused specifically on the subject matter, and we have communicated frequently.

Tower’s proprietary tech tools help prevent Section 111 Civil Money Penalties

In addition to education and communication, with Tower’s focus on technology to measure, manage and drive results, we built a dashboard to steer our clients through MSP compliance so they can avoid CMPs when they go into effect.  See our news release for details: Tower MSA Partners Releases Medicare Mandatory Reporting Dashboard.

Our S111 Management Dashboard gives you the 24/7 data and reporting oversight for every aspect /of the reporting process.  Workers’ compensation and liability payers usually have limited visibility into claims history through their Section 111 providers’ reporting systems.  They may receive compliance error reports but aren’t able to quickly verify compliance accuracy.  Few systems remind responsible reporting entities to update the ongoing responsibility for medicals (ORM) termination dates when claims are settled.

The dashboard gives clients full visibility into their claims from a global level all the way down into the details of a specific claim.  You can manage the accuracy of data, such as ICD 10 codes or ORM to avoid unnecessary conditional payment or MSA exposure in addition to avoiding CMPs.

“The dashboard is intuitive and simple to use,” said Todd Venneri, Business Intelligence Project Manager for BETA Healthcare Group, who tested its features. “The ability to quickly access and verify claim information is invaluable.”

While our intuitive S111 Management Dashboard was being developed, we also updated our client portal and MSP Automation Suite. Keep in mind, Tower’s system was built specifically by us for this industry.  It seamlessly manages Section 111 reporting, conditional payments, Medicare Set-Aside triage, clinical and legal interventions, MSA preparation, and CMS submission activities that take clients through settlement and closure.

We don’t know when CMPs will be announced or how Section 111 civil money penalties will be assessed.  What we do know, however, is that our clear, concise dashboard has replaced uncertainty with knowledge and information.

We are ready and we want you to be ready, too.  If you have not used the dashboard yet, take it for a spin.  Get in touch with Hany Abdelsayed at hany.abdelsayed@towermsa.com or 916-878-8062 for a demo.

Build a Better Tower: Partnerships Speed Settlements of Workers’ Comp Claims with Medicare Set-Asides

March 15, 2021

People sitting around conference table discussing MSA settlements.

Tower MSA Partners knows our strengths.  And we know our business.

We’re in the Medicare Set-Aside settlement business. Everything we do, we do to make workers’ compensation settlements possible — whether they have MSAs or not. Tower has built its business processes and technology around making settlements easier, faster, smoother, and less expensive.

We recognize that the value of an MSA is its ability to facilitate workers’ compensation and liability claim settlement and closure.  We also recognize that MSAs can become stumbling blocks to injured workers and their attorneys when it comes to settling claims.  Since Tower’s goal is to break through all barriers to settlement, we formed a strategic partnership with Ametros, the leader in the professional administration of Medicare Set-Asides.

Helping Injured Workers Settle Well

Ametros, which does not produce MSAs, helps injured individuals manage their Medicare Set-Asides and medical allocations after settlement.  During the settlement process, its team educates injured workers and their attorneys on their responsibilities and the resources available to them through professional administration after the settlement. Ametros frequently attends mediations and settlement conferences to help educate all parties on the post-settlement reality of managing a Medicare Set-Aside and how its services support compliance with Medicare Secondary Payer guidelines.

CareGuard, Ametros’ professional administration service, helps injured individuals navigate the healthcare system after settlement. CareGuard Members receive significant discounts for their injury-related medical and pharmacy expenses, durable medical equipment, home health care, and other services. Ametros handles the payment of all medical bills from their settlement funds and takes care of the Medicare reporting associated with an MSA.

Once injured workers understand they can have these services after they close their claims, they’re more likely to move forward to settle the case.

Many of Tower’s clients already work with Ametros and understand the value they bring. This made the idea of working with Ametros to simplify the settlement process for clients and adjusters a natural evolution.

Taking Work Off the Adjuster’s Desk

To further boost efficiency, Tower and Ametros developed a real-time electronic data interchange (EDI) to exchange MSA, CMS, and settlement data. MSA information is automatically updated directly in Ametros’ system at the time of MSA delivery to the client, enabling the Ametros team to begin educating the injured worker, their family, and attorneys.

This is another way we take work off adjusters’ desks and accelerate settlements that involve MSAs.

Speed Settlements

Recently, Tower launched a new program with Ametros to speed settlements. Using our powerful data analytics capabilities, Tower identifies claims that meet criteria for closure and creates a settlement candidate report. Ametros is then engaged to reach out to these injured workers or their attorneys to offer professional administration as an added benefit and to gauge interest in settlements.

When settlement is indicated, Tower prepares the MSA, executes all cost-mitigation strategies and postures the claim for closure.

This is an exciting new way to proactively address claims that may have slipped out of view and generate interest in settling.  There’s no extra work for adjusters and no cost for the payer until a claim is ready to settle and an MSA is prepared.

Future posts will share other strategic partnerships that Tower has forged to build a better, stronger Tower to help you efficiently and cost effectively settle claims.

Meanwhile, have Tower create an MSA settlement candidate report for you. To learn more, contact Hany Abdelsayed hany.abdelsayed@towermsa.com (916) 878-8062.

Rita Wilson

Chief Executive Officer

 

Related:

Legacy Claim Settlement Initiatives 

 

Building a Better Tower – Cybersecurity

February 18, 2021

hands on a keyboard overlaid with a lock symbol to illustrate cybersecurity

Tower has invested in significant cybersecurity initiatives to “Build a Better Tower” for our clients.  I provided a brief overview of those initiatives in a recent article and this week I highlight Tower’s investment in protecting Tower and our clients’ data.

Tower’s Cybersecurity Defenses

Long before COVID-19 came along, bringing a tsunami of cyberattacks, Tower had already proactively strengthened our internal IT defenses.

During the fall of 2019 we partnered with Vigilant Technology Solutions to use a service that combines passive monitoring technology with certified information security analysts. Through a customized deployment of Vigilant’s NDR (Network Detection and Response) and EDR (Endpoint Detection and Response) technology, Vigilant’s analysis engines and human threat hunting has reduced the time to detect and contain threats by 99.97% over the industry average.  Without this kind of 24/7/365 monitoring and action, bad actors can enter a system undetected and stay there for months learning how to circumvent security measures and destroying backup data resources.

The graph below shows the timeline of the recent attack on SolarWinds that ultimately compromised 18,000 through deployed software.  SolarWinds CEO disclosed an updated attack timeline, indicating that hackers had first accessed SolarWinds on September 4, 2019.  SourceSolarWinds blog, January 11, 2021.

But it is not sufficient to protect our own technology. We also educated our clients and others in the industry so they could understand and prevent cyber threats. Vigilant’s CEO Chris Nyhuis joined our VP of Information Technology Jesse Shade and another expert, Rob Kolb of Premier Mindset, for an eye-opening webinar in February.  It’s available on demand. Jesse also wrote two WorkCompWire articles with excellent advice that you can read here and here.

Third-Party Risk Assessments

In addition to ensuring the protection of its internal data, Tower also implemented a Vendor Risk Assessment Process for all third parties that had access to Tower data or networks or housed servers that stored our data. Our philosophy is that we are only as strong as our weakest link.  The result of this assessment is a vendor management process that continuously measures and monitors our partners to ensure that as per the AICPA Trust Criteria, we consistently honor the commitments made to our clients.

These are just a few of the ways that Tower is continually and proactively enhancing our infrastructure, processes and offerings to deliver measurably better services to you.

Rita Wilson,
Chief Executive Officer

 

Building a Better Tower

February 4, 2021

Man with blocks is building a tower

To master an understatement, 2020 was an unprecedented year of uncertainty and challenge for Tower MSA Partners.

When travel came to a halt and face-to-face meetings, conferences, and other business activities transitioned to a virtual environment, a new “normal” arrived. Tower MSA Partners, like many other companies, acclimated to these changes, believing that we could wait out the pandemic. 

Very quickly though, our leadership team realized that by looking inward, this time of external change could be used as time of growth for our company.  Our introspection produced actions to further strengthen our technology and services and to identify best-in-class partners in order to provide greater value to our clients and to build a “better Tower” for all stakeholders.  

When work from home (WFH) was mandated, Tower managed the transition seamlessly.  With 24/7/365 cybersecurity protection already in place for our network and data, full business continuity was achieved.  We consistently hit our target metrics in MSA turnaround time, cost mitigation and prescription drug treatment reductions without exception.

By looking at the internal controls that protect, monitor, and drive our business, we also created a stronger Tower that included:  Tower that included:

  • Increased cybersecurity – protecting Tower’s network and its clients’ data from a cyber threat.
  • Completed an intense SOC 2 Type 1 audit
  • Pursued strategic partnerships to extend best-in-class service
  • Created and delivered valuable educational content to help clients secure their own systems and data, enhance MSP compliance, and optimize MSAs
  • Introduced a free service — a 2nd Opinion on questionable MSAs
  • Deployed a Section 111 Management Dashboard to easily identify and correct errors, avoiding the potential for monetary penalties

Over the next few weeks we’ll explain these initiatives and others designed to provide secure and cost-effective MSP compliance services for our clients.

Rita Wilson

Chief Executive Officer
 

What Gets Measured Gets Managed…. What’s Your Number?

July 23, 2018

man choosing form icond on a transparent technology touchscreen with a caption by Peter Drucker: "What gets measured, gets managed"

In today’s digital environment, if you are an employer, carrier or TPA, you are likely inundated with data.  You get claims data, medical and pharmacy data, predictive analytics, benchmark performance data, claim reports, drug interaction, duplicate therapy and contraindication notices, even drug triggers like poly-pharmacy notices, opioid utilization reports, and morphine equivalent dosage (MED) outliers.  You digest voluminous amounts of data internally and also receive a plethora of reports from your vendor partners.  With access to so much data, how do you aggregate it into its simplest form, drilling down to the information that actually shows how you’re doing?   Whether you call it ‘key performance indicators(KPIs) or use some other business term, the short answer is “metrics.

In the words of Peter Drucker, “You can’t manage what you don’t measure.”

As a company that deals with volumes of data internally, and as we work to support our clients’ efforts to comply with the MSP statute, Tower is all about metrics and continuous improvement.  Metrics drive internal efficiency improvements, workflow changes to streamline processes and the implementation of technology enhancements to improve our work product and turnaround times.  It’s also how we bring added value to clients to optimize MSA outcomes.  We define, measure and manage the metrics that yield the ”best” balance in care, cost, and compliance and we use these key performance indicators to reverse engineer MSA preparation methodology to continuously improve MSA, CMS approval and settlement outcomes.   We identify the metrics that drive the results we want to see.  We then measure our performance and modify processes, workflow, and technology to improve.

METRICS TELL A SIMPLE STORY

Step #1 is to identify what drives the results you seek to achieve. For example, in the case of the MSA and settlement, most would agree that pharmacy is the single biggest cost driver.  We’ve heard this from clients through the years and we’ve monitored this issue ourselves. Though prescription drug costs have come down over the past year, pharmacy remains the biggest concern expressed by payers when settling claims that involve an MSA.  Yet if asked, would you know what percent of your CMS approved MSAs include opioids, the percent of MSAs that include any pharmacy, or the average cost of prescription drugs on MSAs. You can manage (improve) only what you are measuring.

Measuring 2017 performance in Tower’s total book of business as it relates to CMS approved MSAs and pharmacy costs,

56.9% of CMS approved MSAs with ongoing medical had $0 allocated for pharmacy;

72.7% of CMS approved MSAs with ongoing medical had $0 allocated for opioids. 

We know what drives the results we want to see and we know where we are today.  We’ve measured these metrics for the past 3 years, and continue to monitor to see how we can improve.

ONCE YOU MEASURE, HOW DO YOU MANAGE?  

Tower’s clinical staff constantly examines current CMS performance against the latest state workers’ compensation statutes and associated fee schedules, then overlay this with CMS’s review methodology as defined in the most current WCMSA Reference Guide.   When changes are found, updates are immediately loaded into our system, verified and released.   Getting this process in place took a great deal of time, effort, and technology support, but it was key to our ability to measure performance.  Once in place, it’s now a simple verification, audit and sign-off process each month.

In addition to monitoring external changes, our system also benchmarks every CMS response against our internal best practices in MSA allocation.  This is done by reconciling every line item in every CMS response.  Through this software module, we know exactly how we perform against CMS in pricing, frequency, life expectancy, etc.  This information is stored in real time for every response every day, not via a month-end report or only when there’s a Counter Higher response.  Our system prompts our staff to review and reconcile each CMS response immediately upon upload.

Through our proactive approach to clinical and pricing methodology and our CMS response measurements, we avoid overfunding when we initially draft the MSA.  We are also able to reverse engineer to identify cost drivers and barriers to settlement as part of case triage.  We know which clinical and legal interventions can mitigate exposure because we have the historical benchmarks that measure these results historically.

In tracking CMS results over the past 3 years,

Our pre-MSA intervention model yielded CMS approved MSA savings of 61.4% when initiated before CMS submission.

We’ve also identified the documentation/evidence CMS requires in order to approve changes in medical treatment and reductions/discontinuations in drug therapy and we obtain this up front.

With historical benchmarks and CMS performance data, we can easily discern when we have a basis to challenge CMS via re-review submission, and we know what clinical, statutory and pricing documentation to provide to support our request.   In measuring our CMS re-review performance for all CMS counter higher responses received in 2017,

Average turnaround time for Re-review determination and submission was <48 hours and CMS Re-review success rate was 78.8%.

WHAT DOES THIS MEAN TO YOU?

When evaluating MSP partners, check out their numbers.  Find out:

  • Their success rates for clinical interventions and the average dollars saved because of those interventions;
  • The number of Medicare conditional payment searches and investigations initiated and their success rates for disputes and appeals, including total dollars saved;
  • How many Medicare Advantage plan searches and investigations they’ve conducted;
  • A breakdown of the percentage of CMS MSA approvals, counter-highers and counter-lowers;
  • Percentage of counter-highers submitted for re-review and their success rate.
  • How they leverage Section 111 data to improve accuracy with conditional payments and MSAs.

COMPLIANCE BY THE BOOK, CLOSURE BY THE NUMBERS

If the above resonates with you, I encourage you to check out our new website.  We’ve redesigned the site to better reflect our commitment to MSP compliance solutions, not just services.  Throughout the site, you’ll see metrics like those above, as well as many other key performance indicators that we use to measure performance, manage improvements and optimize outcomes.  You’ll also see specific case studies that demonstrate the successes achieved with MSAs, conditional payment negotiations, physician follow up and clinical interventions, as well as what our clients have to say about working with Tower.

For questions, or to learn more about Technology Driven MSP Compliance solutions, please email us at info@towermsa.com or call us directly at 888.331.4941.

What Do Medicare Part D, Medicare Set-Asides and Parenting Have in Common?

March 2, 2018

parenting - father hugging two young children

For those who have raised children, or are in the process of doing so, one of our biggest challenges is to instill in our children some sort of positive decision-making paradigm in our children.  You can call it religious values, moral absolutes, grounding, or just plain common sense, but as parents, we set boundaries (rules) from the earliest age, and try to be consistent in our enforcement.  Our children may think we’re just mean, but this is a price we’re willing to pay if it helps establish an internal barometer to use when approached by people, thoughts and ideas that challenge them.

In raising my three children, one of the techniques I used was a simple, banded bracelet with the acronym, “WWJD” that is, What Would Jesus Do? This was a popular phrase in the Bible Belt where we lived.  I asked that they look at the bracelet each time they were faced with an obstacle or asked to do something that didn’t quite feel right.  One afternoon, my son was telling a story about something that happened at his elementary school that caused him to look at his bracelet. I was so pleased when he said he actually looked at it!  He then responded, “Mom, I tried to decide what Jesus would do, but had a little bit of a tough time, so I switched it in my head to “WWMD”, and I knew exactly what Mom would do!”  I couldn’t help laughing, but based on his response to the situation, my simple reinforcement worked.  At the same time, this also reminded me that our actions speak much louder than our words….children will “do as we do” long before they will ”do as we say.”

How does this relate to Medicare Part D and Medicare Set Asides?

Each day, one of my first activities is to review my Google Alerts to look for news about NGHPs, Medicare Secondary Payer issues and opioids.  This morning, the article that drew my attention was from MedPageToday.com entitled CMS Proposes Opioid Prescribing Limits for Medicare Enrollees.  My first thought in reading the article was that this was great news.

“We are proposing important new actions to reduce seniors’ risk of being addicted to or overdoing it on opioids while still having access to important treatment options,” said Demetrios Kouzoukas, CMS deputy administrator and director of the Center for Medicare.

“We believe these actions will reduce the oversupply of opioids in our communities.”

Key components of the proposal include:

  • Hard formulary levels at pharmacies that would restrict the amount of opioids beneficiaries could receive
  • Establishment of a safety level of 90 morphine mg equivalent (MME)
  • Limiting the # of pills and days supply in an initial prescription for acute pain

According to Kouzoukas, “these are triggers … [that] can prompt conversations between physicians, patients, and plans about appropriate opioid use and prescribing.”

I then realized what CMS was doing.  CMS was setting boundaries to help physicians, patients and plans make better decisions about opioid use…. the same type of boundaries I set for my children so they would make better decisions as adults.  What a great idea!  If physicians, patients and plans (both Medicare and workers’ compensation) can dialogue before Rxs are filled, better decisions about opioids are inevitable and the frequency of opioid addiction will diminish.

So what’s the problem?

Unfortunately, there remains a problem in the world of workers’ compensation and the WCMSA review process.  While I applaud CMS’s effort, there remains a strong disconnect between CMS’s proactive stance on opioid limitations with Medicare Part D and its opioid-friendly review process for WCMSAs.  At the same time, I must also admit to a similar disconnect between what happens with prescription opioids during the life of a workers’ compensation claim and what we are asking CMS to do when reviewing the MSA at settlement time.  Are we asking  CMS to “do as I say,” instead of providing the example of   “do as I do?”

Can we ‘connect the dots’?

After reading the article, I realized that as an MSP compliance company that has integrated opioid triggers into its Pre-MSA Triage and review process since Day #1, Tower now has a new weapon in its arsenal to assist clients to identify pharmacy obstacles as early possible, and to address issues of inappropriate drug use.  By advising clients to establish and enforce “CMS-like” boundaries at Rx fill time, we have the potential to reduce opioid use in workers’ compensation just as CMS seeks to accomplish with Medicare Part D.  Through such efforts, we can reinforce dialogue between physicians, claimants and workers’ compensation plans before the Rx is filled, and hopefully facilitate better decisions about the first opioid Rx.

And as for the disconnect between Medicare Part D and the WCMSA review process, we cannot force CMS to change its WCMSA prescription drug review process.  We can, however, leverage CMS’s expertise to support better outcomes with Medicare beneficiaries, MSAs and settlements by mirroring their Medicare Part D policies and processes within the workers’ compensation PBM model.  In doing so, we provide CMS with a positive example of their own recommendations implemented successfully, and can hopefully encourage them to “do as we do.

Conclusion

So how do we affect change in opioid prescribing habits in workers’ compensation?  It’s as simple as the bracelet I gave my children.  From Day #1 of a claim involving an active or soon to be active Medicare beneficiary, we continually ask the question, “What Would Medicare Do?” and we execute.

Statement Regarding Hurricane Irma’s Impact on Tower MSA Partners Services

September 8, 2017

As the safety of Tower MSA Partners employees and their families is our utmost concern, Tower MSA’s office in Delray Beach, FL, may be closed on Monday, September 11, 2017, and longer depending upon the impact of Hurricane Irma on South Florida. In anticipation of this closure, we have implemented our business continuity plan which provides for our continued full service to our customers from locations outside of the storm’s path.

With server location for all of Tower’s systems in redundant facilities across the U.S. and relocating Tower staff to multiple backup facilities, business operations will function as normal. All phone inquiries and referrals should be directed to (888) 331-4941 and e-mail inquiries and referrals to referrals@towermsa.com. It is possible that you may experience a slight delay in response, but be assured your request will be handled expeditiously.

For urgent requests, additional contacts are as follows:

1. Compliance questions regarding conditional payments, MSAs and CMS submissions may be directed to Dan Anders, Chief Compliance Officer, at 847-946-2880.

2. Section 111 questions may be directed to Hany Abdelsayed, EVP of Strategic Services, at 916-818-8062.

3. Clinical MSA questions may be directed to Patricia Smith, EVP of Clinical Operations, at 321-320-1045.

We will continue to communicate post-Irma and advise all once we return to normal operations in our Delray office.

Thank you for your understanding and, most importantly, our thoughts and prayers to those who have been affected and will be affected by this storm.

Rita Wilson
CEO
Tower MSA Partners