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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
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 firstname.lastname@example.org or 888.331.4941.
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 Daniel.email@example.com or (888) 331-4941.
Posted on June 30, 2021 by Tower MSA Partners
With great pride, we announce Jesse Shade’s promotion to Chief Technology Officer. As we continue to build a better tower, we recognize its foundation of technology and the people who manage it.
Technology drives Tower’s Medicare Secondary Payer and Medicare Set-Aside processes. Our technology was designed specifically for MSP compliance processes and MSA best practices with modern development tools. It takes someone with the Jesse’s experience to really understand its complexity to continually enhance, improve and maintain it.
As CTO, Jesse is responsible for the strategic planning, development, and management of Tower’s complex technologies. These include systems architecture, cybersecurity, data transfer, business continuity, and disaster recovery.
Jesse possesses an unusual blend of interpersonal and communication skills as well as technical expertise. He is a valued member of Tower’s executive leadership team, responsible for strategic planning and the education of clients and other stakeholders.
He belongs to the Forbes Technology Council, an invitation-only community of world-class CIOs, CTOs, and technology executives with track records of successfully impacting business growth metrics. A thought leader in the areas of technology and security, Jesse has presented and written on these topics, while working closely with CEO Rita Wilson to ensure that Tower has state-of-the art technology and security.
During the pandemic, he managed the work-from-home technology transition and successfully defeated countless cyberattacks. Jesse also designs and develops new products like our S111 Dashboard to help clients maintain Section 111 reporting compliance that launched along with a major upgrade to the client portal and MSP Automation Suite. Most recently, he was instrumental in helping the company successfully complete its SOC 2 Type II audit.
This is Jesse’s third promotion since joining Tower in 2017 as Director of Information Technology, bringing with him 35 years of experience in IT in the insurance, aviation, healthcare and other industries. He became Senior Vice president of Information Technology two years later. Congratulate Jesse by emailing firstname.lastname@example.org.
Posted on May 27, 2021 by Tower MSA Partners
Trying to bring more of your legacy claims to settlement?
This could be the most valuable webinar you’ll ever attend!
Do you have aging claims that continue to draw down on indemnity and medical reserves? Perhaps there is no ongoing medical, but the injured worker was unwilling to settle. Or maybe a claimant is willing to settle, but a prior MSA placed settlement out of reach.
These legacy claims can be settled with a program that aggressively addresses Medicare Set-Aside (MSA) cost drivers and mobilizes a settlement team that paves the way to claim closure–without increasing your adjuster’s workload.
You are invited to join Hany Abdelsayed, Tower’s expert in legacy claims settlement initiatives, for a fast-paced webinar on Thursday, June 24 at 2 p.m. Eastern. You’ll learn about:
- Recognizing legacy claims both obvious and hidden
- Identifying MSA cost drivers, which impede settlement
- Clinical interventions that contain MSA costs
- Settlement partners who clear the path to settlement/claim closure
A Q&A session will follow the presentation. Please click the link below and register today!
Posted on May 20, 2021 by Tower MSA Partners
Tower believes strongly that the true business value of a Medicare Set Aside (MSA) is in its ability to facilitate the settlement of a workers’ compensation claim. Dan Anders shared insight on this topic in this week’s WorkCompWire’s Leaders Speak column, Getting Real Value out of Your MSA.
Some WC payers see an MSA as a necessary evil when it comes to trying to settle a claim with an injured worker who is at or near Medicare age. They have an MSA company tally the future medical and pharmacy costs and either accept the allocated cost as is or freeze in sticker shock and put off any thought of settlement. They might even settle part of the claim and choose to keep medicals open and remain at the mercy of medical inflation.
But there’s another, better option: use the MSA as a settlement tool. Dan’s article lays out the facts and shows you how to use an “optimized MSA” and settlement partners to settle a workers’ comp claim.
What is an Optimized Medicare Set Aside?
The word optimize means “to make as effective, perfect, or useful as possible.” For Tower, a useful MSA helps settle a claim. An effective MSA achieves the perfect balance of care, compliance and cost.
Tower reviews the claimant’s medical records carefully for cost drivers – things like brand name drugs when generics are available or discontinued medications and inappropriate or open-ended treatment. Once these are identified, we recommend clinical interventions. With our clients’ approval, we implement these interventions. Our Physician Follow-up service, offered at no charge when preparing an MSA, clarifies medical treatment and drug regimens with the treating physician(s), escalates the case to Physician Peer Review when needed, and obtains physician statements that document current, appropriate treatment in language CMS can use to approve the MSA.
We make MSAs as useful as possible, and we know how to build a great team of settlement partners. Don’t settle for less.
If you have questions about settling with a CMS-approved MSA – or without one – or want to talk about any Medicare Secondary Payer compliance issue, contact Dan Anders at Daniel.email@example.com
Related Prior Posts:
Posted on May 14, 2021 by Tower MSA Partners
According to the American Nurses Association (ANA), May is Nurses Month, dedicated to honor, thank, and support nurses and all those in the nursing profession. They’ve designated the 2021 theme as “Nurses Make a Difference.” Plus, ANA joins the World Health Organization (WHO) and global colleagues in extending the Year of the Nurse into 2021.
Tower Nurses Make a Difference
We couldn’t agree more with the sentiment that nurses make a difference, and we join in the salute. At Tower, nurses are an integral part of our team. RNs, who hold the Medicare Set-Aside Consultant Certification (MSCC), prepare Medicare Set-Asides (MSAs). Tower nurses review, analyze and summarize medical records and allocate care based upon Tower’s clinical standards, evidence-based medicine, and CMS MSA guidelines.
Their scrutiny often turns up gaps in care, open-ended treatment, treatment of unrelated body parts, discontinued or inappropriate prescriptions, dangerous dosages, and opportunities to switch brand drugs to generics. Once our nurses identify ways to reduce costs without compromising an injured worker’s care, specific clinical interventions are recommended to our clients.
Separate from the nurse preparing the report, a nurse-led clinical quality assurance team the accuracy of the report and makes sure all cost-containment opportunities have been considered and are presented to our client delivery of the MSA report. Subsequently, clinical interventions, such as Tower’s Physician Follow-up service, work to obtain a physician statement and document the current, appropriate treatment in language that CMS can use to approve the MSA as written.
The difference our nurses make can be measured in Tower’s key performance indicators, which reveal a median CMS-approved MSA of $23,205. In addition, only 40% of our CMS-approved MSAs allocate for prescription medications, and 83% of them are approved without post-submission development letters. This record of success would be impossible without the dedication of our nurses. Thank you!
Nurses Month: Stories from the pandemic frontlines
Beyond our gratitude for the nurses on our own team, for Nurses Month, we pay tribute to nurses everywhere and in every role. Nurses have been everyone’s lifeline during the pandemic but have paid a toll for the crucial role they played. We’ve compiled some stories about the experience of nurses over the past year that we found noteworthy.
What Nurses Want You to Know About the Past Year – In this article for AARP, Michelle Crouch gathers nurses’ reactions to the past year. Nurses say that the sheer number and pace of coronavirus fatalities was overwhelming; keeping families apart was painful; mourning patients who died was painful; fear for their own and their family’s safety was a constant backdrop. They are emotionally and physically exhausted. How can we best thank and support them?
“The best way the public can support nurses right now is to get one of those vaccines, nurses say. “Please, go and get vaccinated,” Carrell-Yoder stresses. “We don’t want to do this again. We don’t want more people to die.”
“All Hands On Deck”: The COVID-19 Pandemic Through Nurses’ Eyes – The Dose Podcast from Shanoor Seervai for the Commonwealth Fund looks at the experience of frontline nurses one year into the pandemic, with many experiencing stress, grief, and fatigue. Her guest is Mary Wakefield, a nurse and a professor who has held positions in the Obama administration and in the Biden-Harris transition team. When asked about lessons learned for going forward, Wakefield said:
” … our public health infrastructure, as many people recognize clearly now, is incredibly anemic. The largest proportion of public health workforce is comprised of nurses, and yet they’re still too few. We’ve seen an erosion in the United States public health infrastructure over the last number of years. That has got to be built back up. We need more public health nurses. Not the same, we need more.”
Nursing in the time of COVID-19: Two advanced practice nurses on the front lines of the pandemic – Johis Ortega and Juan M. González are advanced practice nurses and professors at the University of Miami’s School of Nursing and Health Studies. Ortega also serves as Associate Dean for Hemispheric and Global Initiatives at the school and González is Director of the Master’s Program in Family Nursing. In a story for the Pan American Health Organization (PAHO), they offer a portrait of their experience in treating patients in the peak of the pandemic.
It’s Always Been Tough Being A Nurse. Now It’s Worse – Tom Lynch of Workers Comp Insider tells us that nurses experience a shockingly high level of on-the-job injuries, including the highest rate of sprains and strains of all professions. And he says that:
“The COVID-19 pandemic has made things even worse. A new Washington Post – Kaiser Family Foundation Poll reveals roughly three out of ten health care workers are considering leaving the profession and more than half report being “burned out” due to the overwhelmingly horrific year they’ve just spent trying, and often failing, to save the lives of COVID inflicted patients.”
Posted on May 11, 2021 by Tower MSA Partners
With a name like “Mandatory Insurer Reporting” and potential reporting penalties of up to $1,000 per day per injured worker, one would think payers would take Section 111 reporting penalties pretty seriously. But since these penalties have never been enforced, avoidance of penalties has not been a top concern.
It looks like Section 111 penalties could be coming soon, though. The Centers for Medicare and Medicaid Services (CMS) positioned itself to implement them by proposing specific regulations last year. The agency solicited comments from stakeholders last April and could publish final regulations at any time.
Tower’s Chief Compliance Officer, Dan Anders, wrote an article in this week’s WorkCompWire Leaders Speak series, Plan Now to Avoid Pending Medicare Reporting Penalties, that recaps the history of Section 111 reporting and outlines reporting errors and CMS’s proposed penalties. And, unlike many articles that just tell you what CMS says, Dan’s piece recommends ways readers can steer clear of potential errors and problems.
Speaking of steering clear, if you’re not already using Tower’s S111 Management Dashboard, ask Hany Abdelsayed to take you for a test drive. Contact Hany at firstname.lastname@example.org or 916-878-8062.
For more details on Section 111 reporting and Civil Money Penalties, check out Dan’s prior posts:
- CMS Section 111 Mandatory Insurer Reporting Webinar Recap
- CMP Comments Submitted
- CMS Issues Proposed Rule for Mandatory Insurer Reporting Penalties
You can always contact Dan with any questions or concerns about this or any other compliance or MSA issues. He can be reached at email@example.com.
Posted on April 28, 2021 by Tower MSA Partners
In our unwavering commitment to data privacy and security, Tower MSA Partners has completed its SOC 2 Type II audit. The SOC 2 Type II audit reports on a service organization’s non-financial reporting controls and processes as they relate to the Trust Services Criteria developed by the American Institute of Certified Public Accountants (AICPA). It tests the organization’s controls related to security, availability, processing integrity, confidentiality, and privacy over an extended period of time.
From the beginning, Tower has been committed to technology driven processes to bring efficiency and measured results to our clients. The SOC 2 Type II attestation demonstrates how our corporate governance effectively assesses and manages risks and ensures the integrity of the systems and processes delivered by Tower and its business partners to execute the same high level of protection throughout the supply chain. I’m extremely proud of this leadership team and its accomplishments.
Conducted by KirkpatrickPrice, the audit verified the fairness of the presentation of management’s description of the service organization’s system and the suitability of the design and operating effectiveness of the controls to achieve the related control objectives included in the description throughout a specified period.
“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 its controls,” said KirkpatrickPrice President Joseph Kirkpatrick.
Related Prior Posts:
Posted on December 29, 2020 by Daniel Anders
Medicare Set Aside (MSA) companies and insurers will soon get help accessing accurate information necessary for Medicare reimbursements and settling workers compensation and liability claims.
Business Insurance’s Louise Esola wrote a nice article on a new law – the PAID Act – that clarifies expenses that workers’ comp insurers may have to reimburse. The article quotes Tower’s Chief Compliance Officer, Dan Anders, who explains how a new law would make it easier for workers’ compensation and liability insurers to determine if Medicare eligible claimants are or were members of Medicare Advantage and Part D Rx Drug Plans. Anders says:
“When preparing to settle a comp claim “everybody thinks we are hunky-dory, and they go and settle the case and a few months later (Medicare) Advantage comes in and sends in a reimbursement claim,” said Mr. Anders, who applauded the change. “This gives (insurers) better information that when the case is settled there won’t be any surprises. … They can investigate any claims for reimbursement and make sure that is resolved, so there are no issues months, years down the road.”
For the full article, see: New law clears air on Medicare reimbursements for comp insurers
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