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CMS releases new WCMSA Reference Guide (Version 3.3)

The Centers for Medicare and Medicaid Services (CMS) has just released their latest version of the WCMSA Reference Guide (Version 3.3, April 19, 2021). This new guide replaces WCMSA Reference guide version 3.2 (October 5, 2020). 

Section 1.1 of the new WCMSA Reference Guide lists the changes made by CMS in this edition.  In general, outside of CMS’s change to Conduent Strataware (“Strataware”) for pricing WCMSA treatment, the changes do not substantively impact the current WCMSA review process, but rather serve to update current CMS WCMSA handling practices.

The following provides a general overview of Version 3.3. updates:

WCMSA Reference Guide (Version 3.3) updates

The main updates made by CMS in the new WCMSA Reference Guide include:

  • An updated link to the current CDC life table used for calculating WCMSAs;
  • Added Strataware website link;
  • Updated the Missouri Major Medical Centers table; and
  • CMS clarifications on the following items:
    • CMS’s method to calculate the seed for structured WCMSAs
    • WCMSAs should include yearly refills for priced IT pumps
    • The CMS consent to release form requires a full signature
    • Instructions for Professional Administrators, who are not the original WCMSA submitter, to contact the BCRC for case access through the WCMSAP.

Impact and considerations

The most significant update in the new WCMSA Reference Guide is CMS’s reference that it is now using Strataware for its pricing of WCMSA services.  While CMS lists its shift to Strataware as one of the new updates, we note that CMS has actually been using Strataware since earlier this year.  Since making this change, we have observed, in general, an increase in CMS’s pricing of procedures, visits, and other treatment services, resulting in higher dollar approved WCMSAs compared to prior years. CMS’s use of Strataware does not impact the pricing of prescription medications.

Outside of this change, the other noted updates have a minimal impact on the current WCMSA process and basically serve to clarify existing practices.  For example, the revised language required structured WCMSAs, requirements for a valid CMS consent form, and the need to add yearly refills for priced IT pumps, are clarifications of existing WCMSA submission and review practices.  

How we can help!

For over a decade, ISO Claims Partners have been the industry leader in providing innovative, cost-effective, and proven allocation services. We offer a host of different future medical allocation services --- including MSAs submitted to CMS; our innovative Evidence-Based MSA (non-submit); medical cost projections; and other proactive services.  We are proud to deliver significant cost-savings for our clients --- as examples, in 2020, we saved our clients over $50M in MSA proactive cost mitigation; $4.5 M in re-review submissions; and approximately $20M through the Amended Review process.  We look forward to learning how we can help you address and reduce your future medical allocation needs!  Please see our Allocation Services Comparison and our Evidence-Based Medicare Set-Aside brochures for further information.


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, 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.

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