Tag: Medicare Secondary Payer Compliance

CMS Solicits Feedback on ORM Termination in Section 111 Reporting

June 1, 2026

cms orm termination and section 111 reporting compliance

In a May 26, 2026, letter to the stakeholder community, the Centers for Medicare and Medicaid Services (CMS) requested feedback on the voluntary termination of Ongoing Responsibility for Medicals (ORM), as it relates to Section 111 reporting.  Per the letter:

Currently, Chapter III, Section 6.3.2 – ORM Termination, provides various scenarios under which an RRE may terminate their ORM status when such status appropriately ends. DMPO desires industry feedback on whether the current parameters are appropriate, reasonable, and sufficient.

DMPO requests that any person or entity desiring to share feedback, ideas, concerns, or questions do so no later than June 9, 2026. Feedback need not be in any formal format or follow any particular parameters. DMPO is unable to guarantee a direct response to all feedback but will take all submissions into consideration as the policy around ORM termination is reviewed. Comments received after the above date will still be considered for future enhancements.

All submissions should be e-mailed to the new DMPO-managed mailbox relating to all Coordination of Benefits and Recovery (COB&R) inquiries:

COBR@cms.hhs.gov

ORM termination is critical not only to ending a payer’s responsibility for payment of injury-related medical care but also to allowing the injured claimant to access medical benefits for injury-related care. Even when care is not injury-related, an open ORM can still result in Medicare denying payment for medical care based on the false assumption that the treatment is related to the injury.

Tower MSA Partners will provide feedback to CMS. We encourage our client partners to share their feedback or reach out to us so we can relay your comments and concerns to CMS. Please contact Tower’s Chief Compliance Officer, Dan Anders, at daniel.anders@towermsa.com.

Premier Webinar: Easy MSA Cost Savings Through Structured Settlements

May 18, 2023

Tower MSA Partners webinar on structured settlements for Medicare Set-Asides cost savings and compliance.

One of the easiest ways to lower the settlement cost is through a structured Medicare Set-Aside. Not only does this reduce the payer’s cost of funding the MSA, but it also provides the injured worker a consistent stream of funds for injury-related medical care over their lifetime.

 On June 7 at 2 pm (EDT) Tower will present an informative session on structured settlements for MSAs. Tower’s Chief Compliance Officer will moderate a special guest panel from Arcadia: Alisa Hofmann, Vice President – Workers’ Compensation and Medicare Practices and Lori Vaughn, Director of Arcadia Client Programs. This hour-long webinar will show how structured MSAs can benefit all stakeholders in a settlement – the injured party, Medicare and the insurance carrier or employer.

Attendees will learn:

  • How to work with a structured settlement provider to incorporate an MSA structure into settlement.
  • The methodology CMS uses to calculate a structured MSA.
  • Rules around converting a CMS-approved lump sum MSA into a structured MSA.
  • The role of a structured settlement broker pre-settlement, during settlement negotiations and post-settlement.

A Q&A session will follow the presentation, and you can provide questions you’d like to have answered when you register. Please click the link below and register today!

Please note that there is no CEU credit offered for this webinar.

Register here.

About Alisa Hofmann:

Alisa is the Vice President of Workers’ Compensation and Medicare Practices at Arcadia Settlements Group and currently works on the Business Development team. She has been handling and overseeing Workers’ Compensation claims for almost three decades with various national carriers.  Alisa obtained her BA in Organizational Communication at Otterbein University. She maintains her adjuster licensing in many states, also holds Life, Health, and Accident Licensing, and many Insurance Accreditations. Alisa has been an active member of the National Structured Settlement Trade Association since 2019, and a member of The MSP Network where she serves on the Professional Administration and Structure-Education Committee.

About Lori Vaughn:

Lori Vaughn has 15+ years of experience in the structured settlement industry and currently oversees structured settlement programs for multiple workers’ compensation and private insurance carrier clients. She leads teams of consultants, case managers, and corporate employees, and is the primary point of contact for the corporate management team for each client. Lori obtained her BS in Kinesiology from California State University, Fresno, and her MS in Kinesiology from California Baptist University. She holds her Life, Health, and Accident licenses in many states and is a member of the National Structured Settlements Trade Association.

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

January 26, 2023

Business professional seeking guidance on Medicare Set-Aside allocation in Tower MSA Partners article.

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.