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.
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If you have questions or would like more information, please feel free to e-mail the author at Sidney.Wong@verisk.com.