CMS Moves Start Date for WCMSA Reporting to April 2025

April 23, 2024

CMS delays start date for section 111 reporting of WCMSAs

CMS delays start date for Section 111 reporting of WCMSAs to April 2025 and announces new webinar for Q&A

During last week’s webinar, the Centers for Medicare and Medicaid Services (CMS) announced an extension of the start date for Section 111 reporting of WCMSAs from January 2025 to April 4, 2025.

(Due to technical difficulties with the April 16 webcast, CMS has scheduled another webinar for Q&A this Thursday, April 25, 2024, at 2:30 ET. Details on the webinar are here.

Remember, CMS requires Section 111 reporting of WCMSAs of any MSA amount, even if $0. These amounts must be reported whether they are CMS-approved MSAs or not.

CMS details new reporting guidelines and start date for Section 111 WCMSA Implementation

CMS reiterated several points that had been detailed in a prior webinar and through the recent Section 111 User Guide update.  Please review CMS Updates Section 111 NGHP User Guide and WCMSA Reference Guide for this information. New points are below:

  • The start date for WCMSA reporting was changed from January 2025 to April 4, 2025, to give Responsible Reporting Entities (RREs) more time to make the needed changes to their reporting processes.
  • Testing of the new fields will be available beginning on October 7, 2024.
  • All WCMSA fields except Field 43 (Professional Administration EIN) will result in “hard” errors if reported incorrectly. Hard errors cause the TPOC report to be rejected, which can in turn cause the report to be untimely if it is not corrected promptly.
  • As such, hard errors may result in the imposition of civil money penalties (CMPs) although CMS will not impose a CMP for two reporting periods after implementation of WCMSA reporting. In other words, only records on or after October 15, 2025, and with a reportable MSA are subject to a CMP.
  • If an RRE fails to report an MSA, CMS may utilize all available statutory and regulatory options to recover mistakenly made payments, including under the False Claims Act.
  • No changes are made as to what constitutes a reportable TPOC. If a TPOC is reportable, then the WCMSA fields must be completed. If it is not reportable, such as when the WC settlement is $750 or less, then the WCMSA fields are not completed.
  • If multiple defendants are parties to a single settlement, they must report the total TPOC amount (and not their “share”) and the total MSA amount.
  • The Section 111 reporting process is not intended to replace the submission of settlement documents to CMS following the settlement of a claim with a CMS-approved MSA. (Final settlement documents should always be sent to Tower for upload to CMS.)
  • Receipt of the MSA report through the Section 111 reporting process will allow CMS to send information to the beneficiary on the attestation and exhaustion process. (Currently this is not done for most self-administered non-submit MSAs).

CMS outlines impact of “W” records in common working file (CWF) for MSA reporting

CMS also explained that once the MSA is reported, a “W” record will be posted in the Common Working File (CWF), which prevents payments of medical services related to the reported diagnosis codes. The CWF is part of CMS’s system to accurately coordinate benefits, so Medicare does not make payment when another “primary payer” is available.

A copy of the webinar slides can be found here.

Please contact Dan Anders at with any questions.

CMS Sets April 16 for Webinar on Section 111 Reporting of WCMSAs

March 27, 2024

Webinar on Section 111 Reporting of WCMSAs

Prepare for Change: CMS Webinar on Expanding Section 111 NGHP TPOC Reporting to Include WCMSA Information

The Centers for Medicare and Medicaid Services has scheduled a webinar for April 16, 2024, at 2 PM ET to provide updates on the implementation of Section 111 reporting of Workers Compensation Medicare Set-Asides (WCMSAs).  Per the March 25, 2024 announcement:

CMS will be hosting a second webinar regarding the expansion of Section 111 Non-Group Health Plan (NGHP) Total Payment Obligation to Claimant (TPOC) reporting to include Workers’ Compensation Medicare Set-Aside (WCMSA) information. After the first webinar in November, CMS received additional questions and feedback from the industry. The intent of this webinar is to ensure that RREs will be prepared for the change once implemented. With that in mind, this webinar will include a background recap, summary of technical details, updated timelines and CMP impacts. The presentation will be followed by a question and answer session. Because this expansion impacts reporting of WCMSAs, it is strongly recommended that Responsible Reporting Entities (RREs) that report Workers’ Compensation settlements attend.

There is no pre-registration for the webinar.  Full details can be found here.

As of April 4, 2025, TPOC reporting must include Workers’ Compensation Medicare Set-Aside Arrangements (WCMSAs). (See CMS Sets Date for Start of Section 111 WCMSA Reporting).

The WCMSA reporting requirement applies to both CMS-approved and non-approved MSAs.  This information must be reported if the insurance type is workers’ compensation and the TPOC amount is greater than $0. The rule will be prospective only, meaning it applies to TPOC dates of April 4, 2025 and later.

To collect this data, CMS is adding new fields to the Section 111 Claim Input File.

Tower will provide a post-webinar summary.  If you have any questions, please contact Dan Anders at or 888.331.4941.


Risk & Insurance: Am I Allocating Enough for a Medicare Set-Aside? Take These Pointers from a Pro to Find Out

January 26, 2023

Man in business suit looking confused about Conditional Payments

Tower’s MSP Compliance blog analyzes the nuances of Medicare Set-Asides (MSAs) and other aspects of Medicare Secondary Payer Compliance. It covers topics like re-reviews and the termination of ongoing responsibility for medicals (ORM), along with tweaks to WCMSA Reference Guide. Most of our posts drill down into the fine details that our readers need to know.

Every now and then, though, it’s good to pull back and take a high-level view of MSAs as our Chief Compliance Officer Dan Anders does in this Risk and Insurance article. Keep it handy in case you need to explain MSAs to an injured employee … or a colleague.

Happy Holidays From Your Friends at Tower MSA Partners

December 21, 2022

Happy Holidays sign

We’ve had an exciting year of growth at Tower MSA Partners in 2022 and would like to extend our appreciation to you, our valued partners, who have supported us.  Whether this is your first year as a Tower client, or one who has been with us for many years, Tower’s success results from your loyalty.

Our team works diligently each and every day to earn your trust by providing a service level unmatched in the MSP industry.  And we can do that only through the expertise, knowledge, professionalism and commitment of our amazing staff, also unmatched in our industry Together with our team, we hope we have met and exceeded your service expectations throughout the past year.  

We extend our warmest wishes to you and yours. A Merry Christmas and Happy Holidays from your friends at Tower MSA Partners. 


AASCIF Publishes Tower Article on MSA Submit vs. Non-Submit Debate

December 12, 2022

Tower MSA Logo used in an article on Am I Allocating Enough for a Medicare Set-Aside

In its fall newsletter, the American Association of State Compensation Insurance Funds (AASCIF) published an article entitled “Despite the Controversy, MSA Submission is Still Okay.”  Written by Tower’s Chief Compliance Officer, Dan Anders, the article details the pros and cons of Centers for Medicare and Medicaid Services (CMS) approval of an MSA.

As the article concludes, “While the submit vs. non-submit dispute will undoubtedly continue, the MSA approval process allows parties to obviate the risk of shifting future injury-related medical care to Medicare by obtaining a stamp of approval.”  Recognizing that the submission process can sometimes increase settlement costs, the article provides tips on obtaining a quick CMS MSA approval and reducing cost drivers.

CIO Review Magazine Ranks Tower MSA Partners Among Top 10 Compliance Technology Services Companies

November 3, 2022

Pict of award congratulating Tower on its Technology

The honors keep coming. Earlier this year, Tower ranked in South Florida Business Journal’s Top 25 Women-Owned Business list and now there’s national recognition of our technology driven compliance services. CIO Review: The Enterprise Technology Magazine just listed us among its 10 Most Promising Technology Compliance Services Companies for 2022 and featured Tower in this article.

When our Co-founders Rita Wilson and Kristine Dudley looked at the Medicare Set-Aside (MSA) landscape back in 2010, they found it littered with paper and inefficient processes. Everything was manual. Few providers tried to mitigate costs. And MSAs took so long to produce that some settlements fell through.

After talking with prospective clients to determine their pain points, Rita and Kristie knew they needed to accelerate MSA production. They automated Medicare Secondary Payer (MSP) compliance and MSA best practices into Tower’s MSP Automation Suite.

Because the suite easily integrates with any claims system and gathers data needed to prepare the MSA, it immediately reduced payers’ administrative burden. For the first time, clients also had 24/7 visibility into the entire claim. They could pull reports and check the status of an MSA anytime.

The suite also prompts for next steps and missing data to help keep claims moving. MSAs can be produced in days instead of weeks.

Tower’s MSP Automation Suite was designed so modules could be easily added to quickly adapt to changes from the Centers for Medicare and Medicaid Services. For example, when the agency announced plans to impose high penalties for inaccurate or slow Section 111 Mandatory Insurer reporting, Tower built a dashboard to steer compliance efforts to help clients avoid these future penalties.

The technology helps us mitigate MSA costs and immediately implement CMS changes. It also makes compliance more efficient for Tower’s clients and employees.  It frees our professionals to concentrate on clinical and legal interventions to reduce allocations and focus on our clients.

One of our clients said,Tower MSA has been a great partner for us! I have been very impressed with their level of communication and availability to help answer questions. Their easy referral process and fast turnaround times are much appreciated.”

Naturally, we enjoy external validation from honors like the CIO Review recognition. But it’s a real honor to serve our client partners who are some of the most respected payer organizations in the industry.

We’re constantly looking for ways to improve, meet clients’ needs, and exceed their expectations. Please contact Rita Wilson, with any questions, suggestions, or other ideas.

Tower MSA Partners’ WCI-TV Interviews Reveal How Workers’ Compensation Companies Use Claims Data

August 19, 2022

WCI TV logo for ads on Data analytics

The workers’ compensation industry has extolled the promises of data analytics and automation for years.

But how are organizations really using claims data?  What strategies have worked best? And what have they learned?  Several executives will share their experiences during WCI-TV interviews sponsored by Tower MSA Partners.

Guests include Dave Strange, the Yellow Corporation’s Workers’ Compensation Manager and Greg Hamlin, Senior Vice President, Resolution with Berkley Industrial Comp. Ametros CEO Porter Leslie and Alisa Hofman, Vice President of Workers’ Compensation and Medicare Practices for Arcadia will discuss the use of data during and after settlement.

In addition, Tower’s Chief Compliance Officer Dan Anders and Chief Operations Officer Kristine Dudley will share how the technology driven company uses data to streamline Medicare Secondary Payer compliance, protect clients from penalties, and optimize Medicare Set-Asides.

Tower has been the exclusive sponsor of WCI-TV since it first aired in 2015. WCI-TV airs throughout the convention center, in hotel guest rooms and shuttles, on You Tube and CI’s website. Tower’s interviews will also be shared on the company’s LinkedIn page.

 The 76th Annual WCI Conference will be held August 21-24 at the Orlando World Center Marriott. For more information, please see


Catch Tower’s Dan Anders on the popular ADJUSTED podcast

July 13, 2022

Dan Anders who was quoted in the Claims Journal

The latest episode of the popular ADJUSTED podcast features our Chief Compliance Officer Dan Anders on one of his favorite topics, Medicare Set-Asides. When are they needed? How do you mitigate their costs? What’s the deal with rated ages? Host Greg Hamlin and Guest-host Matt Yehling, Director of Claims at Midwest Employers Casualty wanted to know.

The hosts posed the all-important question of when should workers’ comp claim with a Medicare beneficiary claimant be settled: now, later or not at all? Dan guides listeners through the various elements to consider when coming to this decision. Is the Medicare beneficiary’s condition stable? Is surgery imminent? Are they still tapering off certain medications? Are there ways to lower costs without compromising care? What are the barriers to Centers for Medicare and Medicaid (CMS) approval?

While talking about ways to mitigate costs, Dan stresses the need to obtain physician statements to clarify treatment, including which medications are discontinued. CMS requires the costs for these to be included in the MSA unless changes are documented in certain ways. Tower’s Physician Follow-up service does this and has been used on nearly half of our CMS-submitted MSAs.

If you’re new to MSAs or need to know more about reducing their costs, this podcast is for you. Find it on Apple, Google, Spotify, other platforms and here: Medicare Set Asides with Dan Anders (

Even better, you’ll learn a little more about Dan. Did you know he considered a career in politics?

Produced by Berkley Industrial Comp, ADJUSTED presents interviews with experts on a variety of topics touching workers’ comp. Other recent episodes on settlement issues were Ametros’ Andrea Wells and Brad Cantwell with Arcadia Structured Settlements. Visit the Berkley Industrial Comp blog for these and more.

MSAs are complicated and confusing—they even stump the specialists at times. Sometimes you just need to talk to an expert in a certain area. If you ever have a question about an MSA, Dan is happy to talk to you. Get in touch with him at

Related posts

Premier Webinar: Tricks of the Trade for Successful MSA Outcomes

Medicare Set-Asides

MSA Optimization Yields $175,867 in Savings

June 15, 2022

stethoscope and insurance claim form


Tower was engaged to prepare an MSA for a 54-year-old partial quadriplegic. The lack of current medical records, the erratic behavior of the patient, the quality of the provider’s treatment coding, and unknown treatment outside of the WC Plan were challenges to preparing an accurate MSA. The preliminary MSA amount was $424,528.


In review of the treatment records, Tower’s medical experts were able to identify several instances where Medicare covered expenses could be reduced as part of Tower’s Optimized MSA process.

At Tower’s request, the client obtained current medical records. Tower’s clinical team reviewed those records and the corresponding billing codes used for all treatments. By analyzing the provider’s treatment methods against Medicare’s reimbursement requirements, Tower was able to identify items that were more accurately priced with alternative codes. One instance identified was a determination that a catheterization code (A4353) was used incorrectly. By using the correct billing code and applying other cost savings strategies to the treatment regimen, the MSA dollars were significantly reduced.

To ensure that CMS would accept the updated medical coding, Tower detailed how the original billing code was incorrectly used and then provided the correct coding.

RESULTS: $175,867 in Savings

Upon finalization of the optimized MSA, a total allocation amount of $248,661 was submitted to CMS for review and approval. CMS accepted the proposed MSA amount and responded with a Full Approval. Using Tower’s proprietary processes and technology, the client carrier was able to reduce the Medicare exposure of this settlement resulting in total savings of $175,867.

More Tower Success Stories can be found here!

South Florida Business Journal Recognizes Tower MSA Partners as a Top 25 Women-Owned Business

June 9, 2022

banner featuring photo of CEO Rita Wilson and COO Kristine Dudley to announce Tower MSA being named to Women Owned Business list

Tower MSA Partners is recognized as a Top 25 women-owned business by South Florida Business Journal.

We know we’re good, but we enjoy external validation as much as the next guy – or woman. So, we were quite pleased to learn Tower MSA Partners not only made the South Florida Business Journal’s list of Women Owned Businesses, but we ranked among the Top 25.

The publication covers companies in the densely populated Miami-Dade, Broward, and Palm Beach counties. When you consider how many women-owned businesses are in this market, the honor is even more impressive. A 2016 Sun Sentinel story said nearly half of all the women-owned businesses in Florida were based in this area.

Among the metrics used to produce the list is the percentage of the company that is owned by women. For Tower, that’s 100%. CEO Rita Wilson and COO Kristine Dudley co-founded the company more than 10 years ago. You can read more about the company’s start in this article.

Tower is not only women-owned but 85% of our employees, including most of our managers and supervisors are women.

Tower is also a certified member of WBENC or the Women’s Business Enterprise National Council, a leading non-profit organization dedicated to helping women-owned businesses thrive.

If you’d like to connect with Rita or Kristie email them at or