MSP Compliance Blog

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

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

CMS to Host Webinar on PAID Act Implementation and Upcoming Testing

Posted on August 12, 2021 by Daniel Anders

On Thursday, September 9, 2021, at 1 p.m. ET the Centers for Medicare and Medicaid Services (CMS) will be hosting a second webinar on the implementation of the Provide Accurate Information Directly (PAID) Act.  Per the notice:

CMS will be hosting a second webinar regarding the impacts to Section 111 Non-Group Health Plan (NGHP) Responsible Reporting Entities (RREs) related to the PAID Act, which was signed into law on December 11, 2020. The intention of the PAID Act is to help NGHP RREs better coordinate benefits by providing beneficiary Part C and Part D enrollment information via updates to the Section 111 Query Response File. These changes will go into effect on December 11, 2021. This webinar will offer important PAID Act reminders and focus on the details of the upcoming testing period, which will begin on September 13, 2021. The webinar presentation will be followed by a live question and answer session with staff from CMS and the Benefits Coordination & Recovery Center.

Check out slides from the first CMS Provide Accurate Information Directly Act webinar.

If you are a Tower Section 111 reporting client, we recently provided a draft query response file layout.  This layout incorporates the additional fields required to receive Part C and Part D enrollment information and Part A and Part B effective and termination (if applicable) dates.  Tower will initiate testing with the BCRC in September and make changes, if any, to the final file layout before the December 2021 implementation.  Additionally, Tower’s next quarterly webinar (date and time to be announced soon), will address PAID Act implementation and best practices for resolving reimbursement claims from Part C Medicare Advantage and Part D Prescription Drug Plans.

We encourage anyone involved in the Section 111 reporting process to attend the CMS webinar.

If you have any questions, please contact Tower’s Chief Compliance Officer, Dan Anders, at or 888.331.4941.

Related Prior Posts:

CMS: PAID Act Implementation Guidance & New ORM Termination Option

PAID Act Becomes Law


Technology Drives Better Medicare Secondary Payer Compliance

Posted on August 4, 2021 by Tower MSA Partners

Build a better tower with Technology       Building a Better Tower – Through Technology

You may not think about the technology that drives Tower’s Medicare Secondary Payer compliance and Medicare Set-Aside preparation services very often – and that’s understandable.  You may like our simple user interface or the proactive communication our software generates to identify issues, make recommendations, and drive MSA optimization, or appreciate the S111 Management Dashboard, all without thinking about the technology behind the scenes.  That’s ok because we think about it everyday.  In fact, Tower’s  CEO Rita Wilson put technology front and center when she and co-founder Kristine Dudley started the company, automating much of the MSP compliance and MSA preparation operations, quality assurance, and analytics for maximum efficiency, accuracy, and productivity.

With cybersecurity in the news and hurricane season upon us, we wanted to remind you that Tower has you covered in these areas, as well.  Tower stores and manages all data, both internal and client information, securely via a cloud management partner, and has a dedicated “hot site” disaster recovery backup to ensure business continuity should our primary data center fail. For us, business continuity means Section 111 reporting, conditional payment negotiation and resolution, MSA triage, clinical interventions, final preparation, and submission all go on.

“Hurricanes do not affect Tower’s systems, data or internal processes,” Rita explained. “We have employees based all over the country, and before a hurricane impacts our Florida headquarters, our local employees have safely relocated to areas where they can continue to do their jobs with the assurance that the network, infrastructure and cybersecurity protection will be available.  If a natural disaster strikes our primary data center location, an automatic process fails over to our private hot backup site.”

Tower had mastered the IT infrastructure to support a remote workforce long before COVID-19. Aware of steadily increasing cybersecurity threat over the last several years,  the company had already secured Vigilant Technology Solutions’ services for 24/7 monitoring, intrusion detection and prevention.  With VPN access that included multi-factor authentication and secure computer and telephone systems in place, it took less than two hours for employees to transition to work from home

Tower’s complex technology is overseen by Jesse Shade, who was recently promoted to Chief Technology Officer.  This was Jesse’s third promotion in less than four years, which says a lot about how we feel his contributions and talents. Last year, Jesse designed our S111 dashboard to help clients avoid the upcoming penalties associated with erroneous or late reporting and to provide end-to-end visibility to your claims.

This year Jesse worked closely with Rita to secure our SOC 2 Type II attestation.  The SOC 2 audit is designed to give clients and prospects a level of assurance as to how a company organizes and executes its business processes and technology in a structure that provides security, privacy, and confidentiality.

It is one thing for Tower to protect our data and yours, but a major data vulnerability occurs during data transfer between Tower and its business partners.  To ensure that all data exchanged between Tower and any outside entity remains secure, we implemented a third-party risk assessment program to assess and monitor ourselves and our business partners to ensure that privacy, security and cybersecurity best practices are consistently followed.

In addition, Tower is committed to educating clients and other stakeholders.  We hosted a webinar on cybersecurity for our clients and published articles in WorkCompWire last year to help educate others in the industry.

Technology changes all the time, and Tower stays abreast of these changes, always seeking new ways to build a better Tower and a better way to serve the MSP community.  If you have questions about this article or technology in the industry, please contact Rita Wilson, or Jesse Shade,

The Patel Memo Launched the Medicare Set-Aside Review Process

Posted on July 28, 2021 by Daniel Anders

The Patel Memo Launched the Medicare Set-Aside Review Process

Last week, July 23, 2021, to be precise, marked the 20th anniversary of the Patel Memo, which set the stage for the Medicare Set-Aside industry as we know it. Released under the name of Parashar B. Patel, Deputy Director, Purchasing Policy Group for the Centers for Medicare and Medicaid Services (CMS), the memo was directed to the CMS Associate Regional Administrators on the subject of “Workers Compensation: Commutation of Future Benefits.”

It addressed questions sent to CMS regional offices from attorneys who were settling workers’ compensation cases and submitting MSAs to regional offices for review and approval. Although there were some MSAs before this time, the Patel Memo of July 23, 2001, had a pivotal impact and led to the start of several MSA and MSP compliance companies, including Tower MSA Partners 10 years ago.

The memo cited regulatory authority and gave a green light for the regional office review and approval process for submitted MSAs, including criteria and thresholds for review for non-Medicare beneficiary claimants.  It established instructions for the regional office to add the MSA to the CMS common working file and annual accounting requirement for the MSA administrator once the MSA was funded.  The memo also acknowledged structured set-aside arrangements, confirmed that an MSA should be allocated over life expectancy and allowed for fee schedules as a basis for allocating care.

Some of its provisions did not stand the test of time and were eliminated by subsequent CMS memos. These included a prohibition on the use of the MSA funds before Medicare entitlement, indexing the MSA for inflation, and regional office review of the administrative fee and expenses to be charged to the arrangement.

Although the WCMSA Reference Guide officially supplanted the Patel Memo, the memo laid the foundation for the WCMSA review process.

If you’d like to know more about the man behind the memo, listen to this interview conducted by Shawn Deane, General Counsel of our professional administration partner Ametros.

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