CMS Releases Updated WCMSA Reference Guide

By Mark Popolizio  |  January 14, 2015

The Centers for Medicare and Medicaid Services (CMS) has released an updated WCMSA Reference Guide (Version 2.3) dated January 5, 2015.

A copy of WCMSA Reference Guide (Version 2.3) can be obtained here.

This new release represents the agency’s eighth version of the guide to date since its initial release back in March 2013. Version 2.3 replaces Version 2.2 which was released in April 2014.

The changes made through Version 2.3 are outlined in Section 1.1 which can be viewed here.

As will be noted, most of the updates made by CMS pertain to various wording clarifications and other related corrections. Two changes of note include:

  • CMS changed the deadline for responding to development requests for submission through the WCMSA portal from 10 days to 20 days (See Sections 9.4.1 and 9.5).
  • CMS incorporated its new policy related to hydrocodone compounds, which the agency announced by separate notice back in November 2014, into the updated guide. (Section

This policy relates to reclassification of hydrocodone combination products from C-III to C-II controlled substances in October 2014. Under CMS’ new policy, for all new cases submitted after January 1, 2015 the allocation must include a minimum of four healthcare visits per year when schedule II controlled substances (including hydrocodone combination products) are used continuously, unless healthcare provider visits are more frequent per medical documentation.

To learn more about this change, see Section here and ISO Claims Partners’ November 2014 Bulletin article here.

As discussed in our November article, this change will likely have minimal impact on WCMSA allocation costs in most instances since the minimum healthcare provider visits standard implemented by CMS is essentially in line with typical allocation practices in these situations.

Mark Popolizio

Mark Popolizio is the Vice President of MSP Compliance and Policy for ISO Claims Partners. Mark’s area of specialty is Medicare secondary payer compliance. He authors regular articles and provides educational presentations across the country on MSP issues. Mark's e-mail address is