MSP Compliance Blog

Expert summary, analysis and recommendations on issues impacting Medicare Secondary Payer compliance.

Carisk® Partners, Tower MSA Partners, and Ametros to Provide Patient-Centered Case Closure and Settlement Solution in Workers’ Compensation

Posted on October 12, 2021 by Tower MSA Partners

Carisk® Partners, a specialty risk transfer and care coordination company, Tower MSA Partners, a settlement-focused MSP compliance company, and Ametros, a post-settlement medical administration company, are launching a novel, patient-centered case closure and settlement solution. The integrated program provides continuity in care and accurate medical cost projections while improving the settlement process for injured patients and workers’ compensation payers.

“We’re excited to partner with industry leaders Tower and Ametros on this innovative program that extends the trusted relationship built with the patient in our Pathways™ 2 Recovery program,” says Carisk CEO Joseph Berardo, Jr. “This bundled program benefits all parties by ensuring an accurate, fair and acceptable settlement and post-settlement experience for the patients we are entrusted to serve.”

As the patient approaches achievement of their care plan outcomes and goals, the Case Closure and Settlement Program introduces patient settlement resources delivered by Tower and Ametros into the Carisk Pathways™ 2 Recovery (P2R) process.

“Tower identifies all the treatment and legal barriers to settlement,” said Tower CEO Rita Wilson. “With the payer’s authorization, we proactively apply interventions to resolve pharmaceutical, medical, legal, and jurisdictional issues before we prepare a Medicare Set-Aside. This yields appropriate future care for workers’ comp patients, complies with the Centers for Medicare and Medicaid’s review policies, and facilitates closure.  We are thrilled to overlay our settlement-focused workflow with Carisk and Ametros to create win-win outcomes for both payers and patients.”

Ametros advocates for Carisk patients during and after the settlement process, educating them about the multiple benefits available through professional administration of their MSA.

“Our mission is to help the injured person live a better life after they accept a settlement with an MSA. In addition to paying bills from their MSA, providing discounts on their treatments, and completing required CMS reporting, we have a Member Care Team to help them navigate the health care system after settlement every step along the way,” said Ametros CEO Porter Leslie.

This comprehensive solution extends patient advocacy for workers’ compensation patients whose cases Carisk manages during and after their claims settlements by ensuring that their future medical expenses are accurately covered and that the patients receive on-going support post-settlement. Working together, our Case Closure and Settlement Program accelerates claims closure, reducing payers’ claims portfolios, adjuster burdens, along with their medical, pharmacy, and indemnity costs.

To learn more, please contact Kristine Dudley, Tower’s Chief Operating Officer, at (888) 331-4941 or

About Carisk Partners and Pathways™ 2 Recovery

Carisk is a specialty risk transfer, care coordination company serving insurers, government entities, self-insured plan sponsors, and other managed care organizations. With a foundation in behavioral health, Carisk’s end-to-end combined solutions include risk-transfer and care coordination of delayed recovery, complex catastrophic cases and MBHO services. Carisk’s Pathways™ 2 Recovery program guarantees to improve outcomes and reduce overall cost of quality care by applying best practices and a patient-centered approach to manage complex challenges for the Group Health, Casualty and Auto markets. Carisk is the first and only Managed Behavioral Healthcare Organization with dual accreditations from both the National Committee for Quality Assurance (NCQA) and the Accreditation Association for Ambulatory Healthcare, Inc. (AAAHC). Visit to learn more.

About Tower MSA Partners

Based in Delray Beach, Florida, Tower MSA Partners provides MSP compliance and MSA services nationally. The company leverages the latest technology to seamlessly integrate, automate, measure, and manage every process from Section 111 reporting, conditional payment resolution and MSA optimization through claim closure and settlement. Tower is a nationally certified Women’s Business Enterprise (WBENC) and has received its SOC2 Type II attestation. For more information, visit and

About Ametros

Ametros is the industry leader in post-settlement medical administration and a trusted partner for thousands of members receiving funds from workers’ compensation and liability settlements.  Founded in 2010, Ametros provides post-settlement medical management services with significant medical and pharmacy discounts along with automated payment technology and Medicare reporting tools. Headquartered just north of Boston in Wilmington, Massachusetts, Ametros may be reached at 877.275.7415 or via

Tower MSA Partners 10-Year Anniversary and 10 Distinguishing Achievements

Posted on September 21, 2021 by Rita Wilson

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 Non-Submit MSA: A Reasonable Alternative

Posted on September 1, 2021 by Tower MSA Partners

To submit or not submit a Medicare Set-Aside for approval from the Centers for Medicare and Medicaid Services (CMS) has been a hot-button issue for several years.    While some follow a global non-submit strategy others opt to follow CMS’s guidance, where possible, considering a non-submit MSA only in specific situations.   Whether a Non-Submit MSA is utilized for settlement depends on several factors and risk tolerances, and Tower MSA Partners stands ready to analyze your claim and help you decide.

A Non-Submit MSA, sometimes called an Evidence-Based MSA, may be a reasonable alternative when the settlement does not meet CMS’s Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) review thresholds. It may seem obvious to use a Non-Submit MSA when the MSA will not be submitted to CMS, but as the methodology in drafting the Non-Submit MSA varies from CMS policy (as detailed below) some prefer to stick to CMS policy for drafting the MSA, even when not submitted.

Besides utilizing a Non-Submit MSA when CMS MSA review thresholds are not met, as the review process is voluntary, settling parties may choose a Non-Submit MSA even when the review thresholds are met.  This carries with it inherent risks in that CMS takes the position that if the funds set-aside prove insufficient “Medicare will refuse to pay for services related to the WC injury (and otherwise reimbursable by Medicare) until such expenses have exhausted the entire dollar amount of the entire WC settlement.”

A Non-Submit MSA report may have a lower allocation amount than a CMS-approved MSA because of the following features:

  • Full Use of Evidence-Based Medicine – Use of evidence-based medicine, i.e., Official Disability Guidelines (ODG) or state treatment guidelines to determine reasonable care to allocate in MSA.
    • CMS inconsistently uses evidence-based medicine in its MSA review process. Using ODG and state treatment guidelines may result, for example, in a lower frequency of diagnostic testing or physical therapy visits compared to a CMS-approved MSA.
  • Examining Physician Opinions Considered – Both treating and examining physician recommendations are considered in drafting the Non-Submit MSA.
    • CMS gives little consideration to examining physician opinions in its approval process.  Depending on the case, the examining physician may be in a better position to provide appropriate recommendations for current and future medical care because of their expertise and the timing of their opinion.  For example, a recent IME opinion on the necessity of surgery may be followed as opposed to a treating physician recommendation from a year ago.
  • State Statutes and Regulations Followed – Fully follow state statutory, regulatory, and other legal bases for including or excluding care from the MSA.
    • While CMS approval requires an “Alternative Treatment Plan” when medical care is denied through a statutory utilization review (UR) process, a Non-Submit MSA will exclude care solely based on the UR determination.  For example, a prescription medication will not be allocated in the MSA when a UR determination supports denial.
  • Claimant Statements and Agreements Considered – Consideration of claimant statements and settling party agreements concerning future medical care.
    • CMS will not usually exclude the cost of care from an MSA for a procedure or device, such as a spinal cord stimulator, based on a claimant’s statement that they will not pursue that care. Yet that statement or an agreement among the parties that certain medical care is disputed and not included in the settlement, is sufficient for a Non-Submit MSA. For example, evidence of the claimant repeatedly refusing surgery will usually result in its exclusion from the MSA.
  • Professional Administration Recommended: Except for minor MSA allocations, Tower strongly recommends having a professional administrator manage the Non-Submit MSA funds. If CMS ever questions the use of these funds, proper administration will confirm they were spent properly, enabling a seamless transition to Medicare for payment if the funds run out. And, Tower proudly partners with Ametros for professional administration of all MSAs: Non-Submit MSAs and those that are CMS-approved.

Depending on the facts of the case, a Non-Submit MSA can have a significantly lower allocation than a CMS-approved MSA and still reasonably consider Medicare’s interests.  Nonetheless, using a Non-Submit MSA poses risks to the settling parties that should be fully considered and accepted prior to settlement.

Tower offers free consultations on Non-Submit MSAs. If you have any questions about these or other areas of Medicare Secondary Payer compliance, please contact Dan Anders, Chief Compliance Officer, at or 888.331.4941.

Attend the Virtual MSPN Annual Conference!

Posted on August 23, 2021 by Daniel Anders

The National Medicare Secondary Payer Network (MSPN) will hold its virtual MSPN Annual Conference on September 29 and 30.  With the theme of the Roaring ‘20s, the conference celebrates surviving, revamping, and emerging stronger.

MSPN is the only national MSP organization with an influential membership base of claims adjusters, insurance carriers, life care planners, Medicare Set-Aside allocators, nurses, and other medical professionals. Attorneys, professional administrators, self-insured employers, settlement planners, social workers, structured settlement brokers, and third-party administrators are other prominent members. If you’re one of those, work for a self-insured employer, or are reading this post, you should attend.

Open to non-members, the MSPN Annual Conference is designed for insurance, healthcare, financial services, and litigation professionals whose business touch MSP compliance directly or tangentially.  The conference applies for continuing education for multiple licenses and certifications in insurance, case management, legal, disability, nursing and other medical, and disability management fields.

Presented by national leaders in MSP compliance, representatives of CMS and its contractors, the annual meeting examines various aspects of Medicare Secondary Payment.  Sessions dive into Medicare Set-Asides, the recent PAID Act, MSP compliance in Liability, legislative updates, the coming Civil Monetary Penalties for incomplete or inaccurate Section 111 reporting, post-settlement overview, and other timely topics.

CMS Directors and executives from its contractors explain its conditional payment recovery reimbursement and appeals processes in separate presentations. These give you a chance to hear from the folks who make the MSP decisions that determine our compliance.

Plus, Tower’s Chief Compliance Officer and MSPN President Dan Anders (that’s me) will host a lively Fire Side chat with Jackie Cipa, Deputy Director, CMS Division of MSP Program Operations and Steve Forry, CMS Division Director for MSP Program Operations. They will share meaningful takeaways from this year’s annual meeting and highlight emergent issues in the MSP universe.

You can find plenty of information on MSPN’s website about the conference along with early registration fee discounts (Available before Sept. 1).  Remember, the conference is virtual, September 29 and 30 (As the conference is virtual, all sessions will be recorded and may be viewed post the set conference days).  Don’t delay! Register today!

If you have questions about the MSPN or its annual meeting, do not hesitate to contact me at or (888) 331-4941.

PAID Act Implementation How-to Guide Webinar, Sept. 15

Posted on August 18, 2021 by Tower MSA Partners

Join Tower’s Webinar for PAID Act implementation “How to Guide”  on September 15th.

Because of the PAID Act, self-insured employers, insurers and other non-group health plans will finally have access to Medicare Part C Advantage Plan and Part D prescription drug plan information for Medicare beneficiary claimants, starting December 11, 2021. The Centers for Medicare and Medicaid Services (CMS) will provide the data through the Section 111 reporting query process.

While the implementation of these PAID Act requirements is a technical one, it gives rise to many policy questions as to what payers are required to do once they have this data.

Join Dan Anders, Chief Compliance Officer and Jesse Shade, Chief Technology Officer on Wednesday, September 15 at 2:00 PM ET, for a webinar which will tackle both the technical and policy implications around the PAID Act.  Topics include:

  • The Part C and Part D plan identification problem the PAID Act is designed to resolve.
  • Technical changes needed to receive this new CMS data come December.
  • Best practices for handling Part C and D plan data to resolve reimbursement claims from these plans.

Dan and Jesse will describe the steps Tower has taken to ensure our Section 111 reporting clients have a seamless transition to receive the PAID Act data and how Tower can work with you to identify and resolve Part C and D plan reimbursement claims.

A Q&A session will follow the presentation.  Please click the link below and register today!


Related Prior Posts:

PAID Act Becomes Law

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