On June 17, 2025, the Centers for Medicare & Medicaid Services (CMS) hosted an educational webinar titled “Introduction to Workers’ Compensation Medicare Set-Asides (WCMSAs).” In what essentially boiled down to MSA 101, the webinar covered the basics of when a WCMSA is appropriate, CMS submission, funding / administration, and the re-review process. It concluded with a brief Question and Answer segment.
When discussing how WCMSAs fit into the “big picture” of Medicare Secondary Payer (MSP) compliance, CMS was quick to point out that insurers are required to report all situations where they are actively paying for care or have made a payment that releases medicals. This statement undoubtedly served as a timely reinforcement of the mandatory WCMSA reporting requirements, which took effect on April 4, 2025.
Below are some key takeaways from yesterday’s webinar:
CMS Submission
Non-Submit MSAs
Mandatory WCMSA Reporting
Question and Answer
While the webinar highlighted several recent changes surrounding WCMSAs, it also served as a reiteration of CMS’ long-standing positions. CMS’ voluntary review and approval process remains the gold standard to avoid an assumption of payment burden shifting. Although, given the transparency now provided with the newly established WCMSA reporting requirements, there was an expectation of a higher level of acceptance for claims involving Medicare beneficiaries. Additionally, there is no jumping from the hamster wheel of development anytime soon. If parties think that a drop off in treatment and a payment history to match will pass muster for CMS review and approval, think again. To avoid submission delays, parties should ensure a signed statement from a treating physician is provided that clearly indicates the last date of treatment.
Our expert team at ECS continues to closely monitor CMS trends and is here to support you in meeting your Medicare Secondary Payer (MSP) compliance obligations while also achieving the best claims outcomes. Should you have any questions, contact your local or national account manager or Neha Pellegrino at neha.pellegrino@examworkscompliance.com