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

Posted on November 3, 2022 by Tower MSA Partners

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

Posted on August 19, 2022 by Tower MSA Partners

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

Posted on July 13, 2022 by Tower MSA Partners

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

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Medicare Set-Asides

MSA Optimization Yields $175,867 in Savings

Posted on June 15, 2022 by Tower MSA Partners


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

Posted on June 9, 2022 by Tower MSA Partners

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

Tower MSA Partners Receives 2022 SOC 2 Type II Attestation

Posted on May 3, 2022 by Rita Wilson

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 to arrange for a conversation.

Premier Webinar: Medicare Advantage Plan Reimbursement – What Now?

Posted on April 7, 2022 by Tower MSA Partners

In December 2021, the Centers for Medicare and Medicaid Services (CMS) started providing access to data showing a claimant’s enrollment in Medicare Part C and D plans. Now payers are wondering how to best interact with Medicare Advantage (MA) plans and prescription drug plans. What are their reimbursement rights? How does this work with Section 111 reporting?

Tower is pleased to feature a guest presentation by Brian Bargender, Management Consultant, Subrogation and Other Payer Liability for Humana on Wednesday, April 20 at 2:00 PM ET.  Brian is arguably the industry’s foremost expert on Part C and D plan subrogation. Humana is the second-largest Medicare Advantage Plan and Part D plan in the country and has been the leading advocate for reimbursement under the MSP Act.

Here’s just some of what you will learn:

  • Role of Part C and D plans in providing services to Medicare beneficiaries.
  • Reimbursement rights of Part C and D plans under the Medicare Secondary Payer (MSP) Act.
  • Interplay between CMS and Part C and D plans in use of Section 111 Mandatory Insurer Reporting data.
  • Part C and D plans role in Workers’ Compensation MSAs.
  • Best practices for working with Part C and D plans to resolve reimbursement claims.

A Q&A session will follow the presentation, and you can provide questions at the time you register. Please click the link below and register today!


Dan Anders Quoted in Claims Journal on Non-Submit MSAs and Section 111 Penalties

Posted on March 24, 2022 by Tower MSA Partners

CMS is serious about protecting Medicare’s funds. Over the years, the agency has had policies that were not enforced, including sizeable civil monetary penalties for not complying with Section 111 reporting rules and denying payment for medical treatment when another payer was responsible.  But things are changing.  CMS has denied payments and has taken steps towards collecting those penalties.  Claims Journal Editor Jim Sams explores these actions in this piece, which quotes Tower’s Chief Compliance Officer Dan Anders.

CMS Rules on Settlement Reporting May Sting Insurers and Claimants Both (

CMS Clarifies Policy on Non-Submit MSAs in Updated Reference Guide

Posted on March 22, 2022 by Daniel Anders

The January 2022 addition of Section 4.3 to the CMS WCMSA Reference Guide that discussed the agency’s treatment of non-submit Medicare Set-Asides caused quite a stir throughout the MSA industry and raised many questions for those who use non-submit MSAs in workers’ comp settlements.  A February CMS webinar addressed some of those questions and we now have an update (Version 3.6) to the CMS WCMSA Reference Guide that modifies and clarifies this section.

Revisions to Section 4.3

Below is a breakdown of the revisions to Section 4.3 along with comments.

More general language around non-submit MSAs

The original language called out certain MSA products as indemnifying:

“A number of industry products exist with the intent of indemnifying insurance carriers and CMS beneficiaries against future recovery for conditional payments made by CMS for settled injuries.”

The new language is more general:

“A number of industry products exist for the purpose of complying with the Medicare Secondary Payer regulations without participation in the voluntary WCMSA review process set forth in this reference guide.”

Comment:  The original language took aim at MSA indemnification agreements where the new language is broader and includes any product that addresses future medicals. It also reiterates that the CMS MSA review process is voluntary. This was likely in response to people who said that CMS’s original policy changed the MSA review process from voluntary to mandatory.

 ‘May’ instead of ‘Will’ Deny

 CMS’s original policy said that it “will” deny payment of medical services up to the total settlement amount whereas the revised policy indicates CMS “may at its sole discretion” deny payment.

Comment:  It appears that CMS is giving itself wiggle room depending on the circumstances of an individual case.  Also, as is further explained below, CMS has given itself the option to accept less than the entire settlement amount as sufficient to protect its interests.

Total Settlement Definition

The original Section 4.3 defined total settlement as “total settlement less procurement costs.”  This was now revised to define total settlement “as defined in Section 10.5.3 of this reference guide, less procurement costs and paid conditional payments.”

Comment:  Section 10.5.3 is CMS’s longtime definition of “total settlement.” It makes sense that the definition of total settlement in the non-submit context should align. CMS also acknowledges that besides procurement costs, payment of conditional payments from the settlement amount should also be deducted from the amount of the settlement available to pay for future medical.

Post-MSA exhaustion review

When released in January, Section 4.3 provided no option for CMS to acknowledge the non-submit MSA as sufficient. The updated policy now says, “CMS will ignore the non-submit MSA and use the total settlement amount (minus procurement costs and paid conditional payments) as the amount available to pay future medicals “unless it is shown, at the time of exhaustion of the MSA funds, that both the initial funding of the MSA was sufficient, and utilization of MSA funds was appropriate.”

Comment:  It will be the Medicare beneficiary’s responsibility, or someone working on their behalf, to demonstrate that the MSA was sufficient at the time of settlement and that the MSA funds were spent appropriately.  We can assume that CMS will use the standards found in the WCMSA Reference Guide and its MSA Self-Administration Guide to make its determination. If CMS finds either that the MSA was insufficiently funded or inappropriately utilized, does the Medicare beneficiary have a right to an appeal? Medicare beneficiaries have a right to appeal a denial of payment for medical care. Presumably, that right extends to the context of a non-submit MSA, but it remains unclear how this would play out in practice, and CMS did not address it here.

Policy start date:  Per CMS, Section 4.3, “shall apply to all notifications of settlement that include the use of a non-CMS-approved product received on, or after, January 11, 2022; however, flags in the Common Working File for notifications received prior to that date will be set to ensure Medicare
does not make payment during the spend-down period.”

Comment:  Before the January date, there was no obligation to notify CMS of a settlement that includes the use of a non-CMS-approved MSA product (Yes, there is a Section 111 reporting responsibility, but that does not include notification of a non-submit MSA). Is there an obligation now? Nothing in Section 4.3 affirmatively states such an obligation exists and there is no statutory basis that provides for such notification.

Under threshold MSAs:  CMS says “CMS does not intend for this policy to affect any settlement that would not otherwise meet review thresholds. This comment does not relieve the settling parties of an obligation to consider Medicare’s interests as part of the settlement; however, CMS does not expect notification or submission where thresholds are not met.”

Comment:  Again, by saying it does not expect notification where thresholds are not met, CMS implies that they do expect notification when a non-submit MSA is used and thresholds are met. Why would CMS expect no notification on an under-threshold MSA? I suspect there are two reasons:

  • If a claimant is a Medicare beneficiary with a settlement of $25,000 or less, CMS expects that the MSA is a low-dollar amount and not worth the time it takes to coordinate its benefits.
  • If a claimant is not a Medicare beneficiary but has a reasonable expectation of Medicare eligibility within 30 months and the settlement is $250,000 or less, CMS cannot track the claimant as they are not yet a Medicare beneficiary.

Summary comments on Section 4.3 revisions

CMS should be credited for quickly addressing several of the questions and concerns that arose from the original Section 4.3 language. The revised section backs off the seeming implication that the mere use of a non-submit MSA represents a potential cost shift to Medicare. With that said, CMS reiterated that if the non-submit MSA exhausts, then it must be demonstrated that the MSA was sufficiently allocated at the time of settlement and the funds properly expended. As we do not know how this policy will play out in practice, the non-submit MSA route continues to present a notable risk to the claimant Medicare beneficiary.

Other CMS Updates to WCMSA Reference Guide

Beyond Section 4.3, CMS also made updates to other sections of the guide:

Section Most Frequent Reasons for Development Requests

CMS added language to this section around documentation required for disputed cases, in other words, $0 MSAs for denied claims. CMS stated that medical records are required even when the parties are in dispute. Further, draft or final settlement agreements and court rulings are required documentation if they exist.

Comment:  CMS has required the above for quite some time.  This is just putting the requirements into the reference guide.

Section 16.1 Re-Review

CMS added the following to its re-review criteria:

 “Should no change be made upon response to a re-review request (i.e., no error was identified), additional requests to re-review the same error will not be entertained. “

Comment:  Tower has on occasion gone back and forth with CMS on arguments to remove a certain treatment or medication from the MSA. This new statement implies that once CMS makes its decision regarding a particular item it will not entertain other arguments.

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


Marking Insurance Careers Month During “The Great Resignation”

Posted on February 22, 2022 by Tower MSA Partners

How is the insurance industry faring in the choppy waters of “The Great Resignation”? February is Insurance Careers Month, the perfect time to assess where we are after two years of the pandemic.

As a specialty provider of Medicare Secondary Payer (MSP) compliance and Medicare Set-Aside (MSA) services, Tower MSA Partners is a member of the workers’ compensation industry. We’re happy then to commemorate and promote the Sixth Annual Insurance Careers Month. Insurance and related services have been a great career path for many of us at Tower and we’re glad to do our part to raise awareness for the next generations.

At the close of 2021, the Department of Labor/Bureau of Labor Statistics (BLS) put the insurance sector’s employee census at more than 2.8 million employees, with a 1.9% unemployment rate. It’s generally been a stable and resilient business, weathering the pandemic and various other catastrophes fairly well. This is borne out by a new report by Capital Relocation Services (CapRelo), which says that the insurance industry has managed to retain employees relatively better than many industries both in volume and tenure.

But as we look hopefully towards a post-pandemic future, what’s in the cards on the employment front? Will “The Great Resignation” take a terrible toll on the insurance sector as it has with so many other industries?

First, let’s look at what people are talking about when they refer to The Great Resignation.  Start with this:  In December 2021, the “quit” rate was 2.9% as 4.3 million workers voluntarily left their jobs. This was down from November’s highwater mark of a 3.0% quit rate  (4.5 million jobs).  (Source: BLS – Job Openings and Labor Turnover Summary, or “JOLTS” report). This massive flight from jobs is not just happening in the U.S., it’s a global phenomenon, and there are various theories and explanations for why this is happening, with the only commonality agreed upon is that it is related to the pandemic. And there were 4.6 million more job openings than unemployed workers in December. Whatever the reason, it’s an employee’s market, leaving employers struggling to retain and recruit workers.

Industries with low paying jobs and public-facing jobs are among the hardest hit, but there are other reasons beyond low pay and poor conditions that lead to job quits. Gallup surveys put burnout as #1 on the list of reasons why employees are quitting jobs. Feeling unsafe is another frequently cited reason. People don’t want to return to the physical workplace if they don’t feel safe from contracting an illness that they may bring home to children or elderly parents.

But what’s happening to all the workers who quit? Are they just staying home and abandoning the job market entirely?  Well, yes, some are  – in the form of retirement or launching a new business.  Others are seizing the opportunity to trade up on a job, exit a low-paying company/industry, or rethink and re-engineer their career in some other way. While the phenomena of the post-pandemic labor market has been popularly dubbed “The Great Resignation,” other observers think it is more precise to define it as a “Great Realignment” or a “Great Reshuffle.”

In its Q3 2021 U.S. Insurance Labor Market Study and the related whitepaper,  Coming Out Ahead in the Great Reshuffle, The Jacobsen Group, a leading insurance recruitment organization, talked about this:

“While the overall economy is experiencing what many are calling “the Great Resignation,” the insurance industry is encountering more of a “Great Reshuffle.” Professionals who were waiting to make moves earlier on in the pandemic are exploring their options. Individuals are reevaluating their place within their current companies, considering future opportunities and looking forward as offices reopen and the economy continues its recovery.”

In fact, the insurance industry was grappling with certain employment challenges well before the pandemic.  As an industry with an aging workforce, we’ve been faced with the daunting challenge of a retirement talent drain of about half the workforce over the next decade.  And to attract young Gen Z workers and retain millennials, there is the critical need to re-examine and redefine our industry’s value and meaning to generations for whom a sense of  “mission” is table stakes. Plus, as with many long-term industry sectors, there’s been a need to bolster the workforce with deep technology expertise.

Regardless of whether it’s called a great resignation, realignment or reshuffle, employees are sitting in the proverbial catbird seat right now. Insurance organizations need to be proactive in both retaining the talent and expertise they currently have and in retooling to compete aggressively for the talent of the future.

The Transitions

In 2021 a group of leaders in the workers’ compensation industry founded The Transitions with the mission to think strategically about how to handle the influx and outflux of talent over the coming decade.  The Transitions offers an extensive webinar series on such topics as reimagining management style, communication models and technology models in WC.  Additionally, a mentorship program to help recruit and retain talented individuals through professional and personal growth.  We encourage you to check out their website and follow the organization on LinkedIn.

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