Regarding Change to CMS Requirements for Approval of Zero-Dollar MSAs
Effective July 17, 2025, Centers for Medicare & Medicaid Services (“CMS”) will no longer review a Medicare Set-Aside (“MSA”) recommendation for a “zero-dollar allocation.” This change comes as an acknowledgement that the significant time and expense of reviewing these zero-dollar MSAs is of little benefit to the Medicare Trust Fund. What this means is that, going forward, Virginia employers are no longer required to submit for CMS approval an MSA in which Medicare’s interests are valued at $0 (Section 8.1, WCMSA Reference Guide). This is a significant change, given the difficulty in recent years in obtaining zero-dollar allocation approval from...
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