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CMS releases new WCMSA Reference Guide (Version 3.2)

The Centers for Medicare and Medicaid Services (CMS) has just released its latest version of the WCMSA Reference Guide (Version 3.2, October 5, 2020). This new guide replaces the WCMSA Reference guide version 3.1 (May 11, 2020). 


CMS summarizes the updates in Section 1.1, which relate to the major medical centers that the Workers’ Compensation Review Contractor (WCRC) uses to price future medical expenses in WCMSAs. This recent update also moved the “List of Previous Version Changes” to Appendix 8, and designated Appendix 7 as a list of the major medical centers - organized by state, NPI, and zip code.  

Additionally, while CMS has not released an updated version of the Workers’ Compensation Medicare Set-Aside Portal (WCMSAP) user guide, submitters should be aware the WCMSAP includes new features intended to capture the major medical center information. Specifically, when a WCMSA is submitted through the WCMSAP, there’s a new prompt requiring the submitter to confirm whether the WCMSA includes any costs associated with a major medical center and if so, to provide the appropriate zip code.

Claims impact and considerations

Before this update, it was challenging to accurately determine the WCRC’s pricing of facility fees in surgeries and other procedures. This led to pricing variances and significant uncertainty when submitting WCMSAs for review and approval. Now that CMS has disclosed the major medical centers used for pricing WCMSAs, submitters have the missing piece. They can now align those costs in a proposed WCMSA and reduce the number of counter higher approvals attributed to surgery and procedure pricing.  

If you have questions or would like more information, please feel free to e-mail the author at

Sid Wong, J.D.

Sid Wong is the Vice President of Policy at Verisk Casualty. In this capacity Sid monitors and evaluates the changing state of Medicare Secondary Payer compliance to develop impactful solutions to emerging MSP issues and works to ensure that Verisk’s Casualty’s policies, products, and services continue to align with the MSP landscape. He also oversees Verisk Casualty’s policy team, which provides policy and compliance support for all of Verisk Casualty’s clients. During his tenure he has served as Legal Director, Assistant Director of Services, Client Solutions Manager, and MSP Compliance Manager.Sid is a subject matter expert on MSAs, Conditional Payment Recovery, and Section 111 reporting. He collaborates with clients to develop best practices and respond to any compliance or policy questions, whether it’s a case level issue or evaluating a process impacting the larger organization. He regularly presents at industry conferences and provides training for clients.
Prior to joining Verisk Casualty, Sid worked for a small general practice firm in New Hampshire where he received his JD from University of New Hampshire Franklin Pierce School of Law. Sid is a member of the MA, NH, and NY bar, the IAIABC, NAMSAP, MARC, and is MSCC certified.

Brian Cowan

Brian Cowan is vice president of Administration Services, Casualty Solutions at Verisk. You can contact Brian at

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