Identify and Realize Medicare Set-Aside Savings Opportunities

The rising costs of workers’ compensation come in many different forms.  One such way members of the claims management team are seeing these increases is in Medicare Set-aside allocations and future medicals.  This issue presents a challenge for all teams and to meet this challenge a MSA service provider should be utilized that employs creative tools to reduce an allocation in a reasonable and ethical manner.  One such mechanism is the use of physician intervention by following up with the employee’s treating physician to confirm the accuracy of all treatments and prescriptions drugs in the allocation.

 

 

Back to the Basics of MSA Allocation Preparation

 

There is a certain art to preparing and writing a MSA allocation.  This includes the threshold matter of ensuring the allocation is reasonable, and will be accepted if it is sent for voluntary review and approval by CMS.

 

When writing an accurate MSA allocation, the person preparing the report will rely on some or all of the following materials and records:

 

  • All medical records for the last two years of treatment related to the WC claim*;
  • A complete claim payment history record from the insurance carrier;
  • A separate pharmacy payment history report;
  • Draft settlement documents, prior settlements, court orders and decisions and other legal documents;
  • A First Report of Injury; and
  • Explanation of accepted, disputed and denied body parts, along with ICD-10 codes.

 

* “Treatment records” consist of all medical records for treatment to the claimed body part or condition even if the employer or carrier did not pay for the treatment.  Also, CMS does not consider an Independent Medical Examination report a “medical record” for purposes of allocation review and approval.

 

 

Cost Drivers in MSA Allocations

 

Medical costs in workers’ compensation claims continue to rise with a large portion of future medical tied to pharmacy costs. A September 2016 NCCI research brief states “for every $100 of medical services paid on claims older than 10 years, approximately $45 to $50 will be for prescription drugs.” This leads to an increased future medical component that must be considered as a part of every settlement.  Members of the claims management team should monitor their files for the following issues:

 

  • Pharmacy savings opportunities: Medications that are prescribed, but never actually filled by the employee, prescribed medications that have been discontinued, and brand name drugs that can be replaced with generics.

 

  • Medical savings opportunities: Ongoing and prolonged treatment by a primary care doctor for injuries that should require a specialist, gaps in a patient’s medical record and treatment recommendations which are no longer considered viable, such as a spinal cord stimulator.

 

 

Physician Intervention – Brand vs. Generic Drugs

 

There are many opportunities for members of the claim management team to reduce the cost of a MSA allocation and promote a culture of settlement.  One such strategy is directly contacting the employee’s treating physician to follow up on medical cost driver red flags and savings opportunities.  As a note of caution, this should be done in conformance with federal and state law and may require the approval of the injured worker.

 

A classic example of when direct physician intervention is appropriate comes after a review of prescription records.  Often the physician prescribes a certain brand name medication versus a therapeutically equivalent generic.  While not always the case, generics are often considerably less expensive and offer the same medicinal attributes as the brand name.

 

An experienced MSA service provider will notice this opportunity by reviewing the “dispense as written” (DAW) codes in medical and pharmacy records.  They will position your file for the cost-saving measure to recommend direct contact with the physician to revise the prescription for the cheaper alternative.  Communication between the parties allows the necessary change to occur.  The cost savings will be realized once that cheaper alternative is filled by the pharmacy and a paper trail is created.  This allows the allocator to document the file and justify the lower prescription drug costs.

 

 

Physician Intervention – Discontinued Medications

 

Another opportunity for MSA cost reduction is to identify and confirm the discontinuation of medications previously prescribed.

 

Medicare Set-asides: A Case Study

 

 

*case study provided by Tower MSA Partners

 

 

The main cost driver in this MSA allocation was the cost of prescription drugs.  In the above example, a review of the pharmacy recorded revealed Amitiza, Pantaprazole, and Meloxicam were prescribed, but had not been filled for an extended period of time. This represented a significant opportunity for savings by directly following up with the treating physician in writing to confirm these prescriptions had been discontinued. This confirmation allowed the prescriptions to be removed from the allocation, resulting in $200,113 in savings.

 

 

Conclusions

 

The ever-increasing price of medicals on workers’ compensation presents a series of challenges for the claims management team.  In order to avoid over-allocating for treatment and prescription medications, leverage a proactive MSA service provider to identify MSA savings opportunities and intervene with the treating physician.  This proactive approach often results in a lower MSA allocation with realized cost savings to the claims management team.

 

 

For additional information on workers’ compensation cost containment best practices, register as a guest for our next live stream training.

 

Author Michael Stack, Principal, Amaxx LLC. He is an expert in workers compensation cost containment systems and helps employers reduce their work comp costs by 20% to 50%.  He works as a consultant to large and mid-market clients, is co-author of Your Ultimate Guide To Mastering Workers Comp Costs, a comprehensive step-by-step manual of cost containment strategies based on hands-on field experience, and is founder & lead trainer of Amaxx Workers’ Comp Training Center. .

 

Contact: mstack@reduceyourworkerscomp.com.

Workers’ Comp Roundup Blog: http://blog.reduceyourworkerscomp.com/

Live Stream WC Training: http://workerscompclub.com/livestreamtraining

 

©2017 Amaxx LLC. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

CMS Provides Another Piece of the Puzzle on Future LMSA Policy

While the Centers for Medicare and Medicaid Services (CMS) has yet to formally issue a policy regarding review of Liability Medicare Set-Asides (LMSAs), since a June 2016 announcement that it was considering expanding the WC MSA review process to liability and no-fault, CMS has nonetheless provided pieces of the puzzle which will ultimately make up a liability and no fault MSA review process. The most recent piece of the puzzle is an announcement by CMS that effective 10/1/2017, no Medicare payments are to be made to medical providers where a Liability Medicare Set-Aside (LMSA) or No-Fault Medicare Set-Aside (NFMSA) exists.

 

 

Directive To Deny Payment For Care Covered Under LMSA or NFMSA

 

The announcement comes via the issuance of a CMS MLN Matters article directed to physicians and other medical providers submitting claims to Medicare Administrative Contractors (MACs) for services to Medicare beneficiaries. It directs these MACs to deny payment for medical care that is covered under an LMSA or NFMSA as identified in the Common Working File (CWF).

 

To clear up some of these technical terms, MACs process Medicare Part A and B payments to medical providers on behalf of Medicare. A Common Working File (CWF) is maintained by the CMS Benefits Coordination and Recovery Center (BCRC) and contains information on a particular claimant’s Medicare eligibility and, importantly, when Medicare should be considered secondary such that payment to a medical provider should be denied and directed instead to the primary plan.

 

BCRC presently keeps records of all WCMSAs that have been approved by CMS and funded through settlement (This is why CMS requires final settlement documents be submitted to BCRC post-settlement). The WCMSA funding information is placed in the CWF so that the MACs deny payment for medical care associated with the WCMSA until the WCMSA is exhausted. This directive from CMS makes this same process applicable to LMSAs and NFMSAs.

 

 

How Can Medicare Deny Payment Based on Processes That Don’t Exist?

 

In response to this announcement, you would be correct in asking, how can CMS deny payment for medical care based upon an LMSA an NFMSA process that does not yet exist? Putting aside that some CMS Regional Offices have reviewed and approved LMSAs at their own discretion for quite some time, this does pose a very good question. CMS responds as follows:

 

CMS will establish two (2) new set-aside processes: a Liability Medicare Set-aside Arrangement (LMSA), and a No-Fault Medicare Set-aside Arrangement (NFMSA).

 

 

New Set-Aside Process Will Be Put In Place At Future Date

 

So CMS readily admits the new set-aside processes will be put in place at some point in the future. Such future date has already been tentatively set based upon CMS’s release, in December 2016, of its request for proposals for the new Workers Compensation Review Contractor which includes an optional provision to expand reviews to LMSAs and NFMSAs effective July 2018 (See prior blog post: CMS MSA Review Expansion to Liability Planned for 2018). Consequently, this directive to the MACs is implementing medical payment processing changes which will be required to be place once the LMSA/NFMSA review process is made available.

 

It is important to keep in mind that CMS has yet to release any guidance on such an expansion of the WCMSA review process to liability and no-fault and particularly how such a process would differ from that created for WC. Also note that CMS does not state that effective 10/1/2017 the MACs are to deny payment for all post-liability settlement injury-related medical care, rather, they are to “deny payment for items or services that should be paid from an LMSA or NFMSA fund.” The funds must exist for denial to occur. Accordingly, over 2017, as more pieces of the puzzle come together on CMS’s Liability and No-Fault MSA review policy, Tower MSA will provide further interpretation and guidance on what will be one of the most significant developments in MSAs since CMS formalized the WC MSA review process in 2001.

 

 

 

Author Dan Anders, Chief Compliance Officer, Tower MSA Partners. Dan oversees the Medicare Secondary Payer (MSP) compliance program. In this position, he is responsible for ensuring the integrity and quality of the MSA program and other MSP compliance services and products. Based upon his more than a decade of experience in working with employers, insurers, TPAs, attorneys and claimants, Dan provides education and consultation to Tower MSA clients on all aspects of MSP compliance. Contact: (847) 946-2880 or daniel.anders@towermsa.com

 

In a Volatile Political Climate MSAs & Professional Administration Provide Much Needed Assurances

These first few of months of 2017 have been, to put it mildly, volatile in national politics.  The incoming Trump Administration and a Republican Congress are poised to tackle the federal budget, Medicaid, and the Affordable Care Act (Obamacare) among many other federal programs.  All of these issues have sharp partisan divides, however no matter where your views lay on the political spectrum, if you are a professional involved in the workers compensation industry, these issues may have a big impact on how you can be successful at your job.

 

This article looks at what impact the Trump administration and a Republican-controlled Congress may have on Medicare Set-Asides (MSAs) in the context of the legislative and regulatory history of the Medicare Secondary Payer (MSP) Act and how the uncertainty resulting from potential changes to federal healthcare programs results in MSAs and professional administration being even more relevant in the settlement of workers’ compensation cases.

 

 

The MSP Act Has Been and Remains Bipartisan

 

A review of the history of the MSP Act demonstrates a noticeably bipartisan effort to improve and expand its applicability and enforcement mechanisms.  The MSP Act was enacted in 1980 during President Carter’s administration.  Subsequent to its passage, provisions were added over the Reagan, George H.W. Bush and Clinton administrations, all emphasizing Medicare being secondary to group and non-group health plans.  The most notable legislative expansion occurred in 2007 when a Democratic-controlled Congress passed, and President George W. Bush signed into law, the Medicare, Medicaid and SCHIP Extension Act which included Section 111 Mandatory Insurer Reporting provisions for group and non-group health plans.  There also continues to be a decade long effort to pass bipartisan legislation which would implement certain reforms to the Workers’ Compensation Medicare Set-Aside (WCMSA) review process.  While the most recent WCMSA reform bill died in the last Congress it is expected a new bill will be reintroduced in 2017.

 

Besides legislative expansion of the MSP Act, during President George W. Bush’s administration there occurred the release of the July 23, 2001 CMS memo, commonly called the “Patel Memo.”  The Patel memo and subsequent CMS memos effectively formalized a process for CMS to review and approve WCMSAs.

 

MSA reviews continued, Medicare conditional recovery processes expanded and Section 111 was implemented all during the course of President Obama’s administration.  The only legislative change to the MSP Act occurring during the Obama years was the passage of the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act) which was a successful bipartisan effort to address deficiencies identified in the MSP Act, particularly Section 111 reporting and Medicare conditional payment recovery.

 

Since the enactment then of the MSP Act in 1980 it has continued to be expanded and enforced consistently across both Republican and Democratic Presidents and Congresses.

 

Why has there not been a partisan divide? The simple reason is that the MSP Act forces entities other than the federal government to pay which has benefits for both political parties. For Democrats it demonstrates their protecting the viability of a federal government entitlement program while for Republicans it demonstrates their protecting taxpayers by shifting costs away from the government. While the Trump administration has to our knowledge never issued any MSP policy statements, based upon the past bipartisanship on this issue, our expectation is the administration will continue and possibly expand the MSP compliance programs at CMS.

 

 

Uncertainty Over Federal Healthcare Programs to Drive Assurance with MSAs

 

President Trump has indicated repeatedly that he will not reduce benefits to Medicare beneficiaries.  Nonetheless, Medicare beneficiaries are facing premium increases. Notably, a Kaiser Family Foundation report indicated Part D premiums are rising by an average of 9% in 2017.  As for Medicaid, the Trump administration is supporting a block grant program which would give more discretion to the states in formulating and implementing their own Medicaid programs compared to the present process which includes significant federal oversight.  Finally, and most significant, is the Republican-led initiative to “repeal and replace” the Affordable Care Act, commonly known as ObamaCare. These potential changes to statutory programs create uncertainty for injured workers contemplating settlement of medical in their workers’ compensation cases.

 

Uncertainty for injured workers exists with programmatic changes to Medicare and private group health plans which are increasingly driven by a more value-based approach to healthcare delivery.  A value-based approach provides incentives to medical providers to be more cautious with prescribing treatments and medications which may have limited value to the patient.  This is also usually tied in part to a utilization review process which places limits on care through the use of evidence-based medicine.  While in the past some injured workers have settled medical stemming from their work related injury confident that they could shift their ongoing work-related care, if any, to their group health plan, such coverage may now be limited.  And when it comes to shifting costs to Medicare, CMS’s long-standing policy is such costs must be accounted for in an MSA.

 

 

A Flight to Certainty

 

Accordingly, injured workers and their attorneys when settling their workers’ compensation cases will look for certainty where it can be obtained so that they have the assurance of access to medical care for their future injury-related care.  For claimants who are Medicare beneficiaries or are close to becoming Medicare beneficiaries, such assurance can be obtained by a properly allocated MSA which is CMS-approved, when necessary, and professionally administered to maintain the MSA funds over life-expectancy in compliance with CMS rules.

 

A best-in-class MSP Compliance company will provide employers and claimants a reasonable MSA allocation which, along CMS guidelines, properly accounts for future injury-related and Medicare-covered medical care without unnecessary overfunding.  This often includes the company reaching out to treating physicians to confirm current care regimens or clarity regarding ongoing medication and treatment prior to submission of the MSA to CMS.

 

While CMS approval of the MSA and subsequent funding provides assurance at the point of settlement that funds for injury-related medical have been provided, equally important is proper administration of those funds such that an injured worker can be assured the funds for his or her care will last over their life expectancy and that there will be a seamless transition to Medicare for payment if the funds every run out.

 

Professional MSA administration can secure the injured party discounts on their medical treatment, and prescription costs. All the while they are free from utilization review allowing them to not have to worry about their treatment being rejected. Additionally, professional administration can make sure all MSA expenses are accounted for in the eyes of Medicare.  These programs are in place to protect the injured worker post-settlement and ensure compliance with CMS requirements for MSA administration.

 

In this current era of high uncertainty, all parties can rest easy by focusing on known methods to protect themselves and the injured party throughout the claim handling and settlement process.  That’s why many believe it is more critical than ever to obtain an adequate MSA that will cover the ongoing medical care of the injured party and, upon settlement, to have a professional administrator help the injured party make the funds last as long as possible and do all the required Medicare reporting.

 

Author Dan Anders, Chief Compliance Officer, Tower MSA Partners. Dan oversees the Medicare Secondary Payer (MSP) compliance program. In this position, he is responsible for ensuring the integrity and quality of the MSA program and other MSP compliance services and products. Based upon his more than a decade of experience in working with employers, insurers, TPAs, attorneys and claimants, Dan provides education and consultation to Tower MSA clients on all aspects of MSP compliance. Contact: (847) 946-2880 or daniel.anders@towermsa.com

 

Author Porter is the Chief Strategy Officer of Ametros. Prior to Ametros, Porter worked in corporate development, private equity investing and as an investment banker. He has experience leading acquisitions, launching new products and building the teams to support them. Porter has a passion for directing the growth strategy of rapidly growing businesses in the healthcare and financial services industries. pleslie@ametrosfinancial.com

2 New Tricks for New Workers’ Comp Claims

Published originally on February 6, 2017 on WorkComp Wire

 

As discussed in last week’s article, old dogs can be taught new tricks. A proactive settlement initiative can not only get legacy claims off the books, but it can also dramatically reduce costs and improve patient care. In one case, a man who suffered a minor back injury at work more than 25 years ago was weaned off fentanyl, hydrocodone, and several other drugs. The claim’s pharmacy spend went from $1,200 to $600 a month and a settlement is planned.

 

An employer that inherited legacy claims in an acquisition initiated an aggressive settlement program that produced $6.5 million savings on 43 MSAs during a 10-month period.

 

Yes, the settlement initiatives produce excellent outcomes for old dog claims. But the lesson here is that these so-called new tricks are available throughout claims handling. Adopting a settlement mindset from day-one can prevent claims from spiraling out of control and becoming old dogs. Think of the medical and indemnity cost savings as well as litigation costs that can be saved as a result of settling these claims short of attorney referral.

 

Remember these two new tricks:

 

  • Proper medical documentation of a file results in better claims handling. If medical treatment records are missing from the file, prescription history is absent or inconsistent with the medical records, or medical care is left open ended, it is difficult to assess the appropriateness of ongoing and future medical care.
  • Pharmaceutical intervention does not need to wait. A claim must be consistently evaluated for the appropriateness of recommended and ongoing prescription medication use. The addition of opioids weeks into the claim is a red flag. Do not wait until on the brink of settlement negotiations to intervene on prescription medications use, do it now.

 

Clinical and legal partners must drive a successful outcome for employer and employee. Every stakeholder (nurse case manager, adjuster, pharmacy benefit manager, defense attorney, or physician) should watch for red flags and intervene themselves or relay issues to the claims handler to determine the necessary action plan to right the ship before the claim gets more difficult to control.

 

When pursuing a settlement initiative involving complex, “old-dog” claims, savvy payers price out future medical exposure, identify cost drivers, and decide which claims to settle right away and which warrant intervention. The smart payers also learn from these old dog claims and put best practices in place to address cost drivers early on in claims handling. What is the impact of pursuing such a claim strategy? Here are the results from an employer who converted an old-dog settlement initiative into a standard for new claims handling:

 

  • 29% reduction in open claims after one-year
  • 43% reduction in open claim after three years
  • 14% reduction in total costs after one-year
  • 26% reduction in total costs after three years
  • 40% reduction in attorney referrals after three years
  • 25% reduction in pharmacy costs after three years
  • 55% reduction in CMS-approved MSA amounts after three years

 

It’s never too early or too late for clinical intervention on a claim with the purpose of driving a successful resolution to the claim. While old dogs can be taught new tricks, the best strategy is to incorporate settlement initiative protocols into claims handling best practices.

 

 

About Dan Anders

 

Daniel M. Anders, Esq., MSCC is the Chief Compliance Officer for Tower MSA Partners. A certified Medicare Set-Aside Consultant and attorney, he oversees the Medicare Secondary Payer (MSP) compliance program. Mr. Anders is responsible for ensuring the integrity and quality of the MSA program and other services and products and he provides education and consultation to Tower MSA clients on all aspects of MSP compliance.

 

Mr. Anders is the former Senior Vice-President of MSP Compliance for ExamWorks Clinical Solutions and he has extensive litigation experience from his prior position with the Chicago law firm of Wiedner & McAuliffe. He holds a Juris Doctor from Chicago-Kent College of Law and a Bachelor of Arts degree from Loyola University Chicago.

 

Contact Mr. Anders at 847.946.2880 or daniel.anders@towermsa.com

 

 

About Tower MSA Partners
Tower MSATower MSA Partners is a national provider of Medicare Secondary Payer services, including Section 111 Reporting and Conditional Payments along with Medicare Set-Aside preparation, submission and oversight. Its proprietary MSP Automation Technology Suite drives MSP compliance best practices and provides end-to-end visibility into each activity. Tower’s other services include pre-MSA Triage, physician peer reviews, MSA administration, medical cost projections, and life care plans. With more than 50 years combined experience in pharmacy, legal oversight and medical care, Tower proactively stages claims and works collaboratively with clients to identify issues and intervene to modify outcomes. Tower remains involved in the claims, through final resolution, MSA and/or other settlement. This model enables Tower’s clients to provide better care to injured workers, reduce claim and MSA costs, and obtain CMS acceptance of the MSA. For more information, visit www.towermsa.com and subscribe to Tower’s www.mspcomplianceblog.com.

How Old Dog Workers Comp Claims Can Learn New Tricks

Published originally on January 30, 2017 – WorkCompWire

 

By Dan Anders, Chief Compliance Officer, Tower MSA Partners

 

Dan AndersThe saying goes you can’t teach old dogs new tricks. But when it comes to clinically driven settlement initiatives involving complex “old dog” workers’ compensation claims, old dogs can be taught new tricks. What’s more, the lessons learned from old dog claims can become a foundation for “new tricks” that can be applied in the management of all claims, building a best practices model that stops the cycle.

 

“Old dog” claims refer to legacy claims or claims which have been open for some time and continue to draw down on the indemnity and medical reserves as a result of ongoing time off work and/or continued medical care. Old dog claims can come from a merger or acquisition, especially if the companies have different claims management and settlement philosophies. Complex claims that were once in front of an adjuster on a regular basis may also become old dogs when shunted aside by an influx of new claims.

 

Whether triggered by a merger, a change in management or the sheer volume of legacy claims, an aggressive settlement initiative can push many old dog claims to closure, and if not closure, there is clear communication that changes will occur. Whether through settlement or a change in treatment, the “old dog” will learn “new tricks.”

 

Successful settlement initiatives involve multiple partners, first to identify and analyze cost drivers across a large number of old open claims, then match them with appropriate interventions (file review, physician peer review, clinical oversight, legal action) to resolve all issues blocking settlement. Once the obstacles are addressed, the next step is to work with the settlement partner to create an incentive for both injured worker and payer. If settlement can be achieved, it is a win, win for all stakeholders. If settlement isn’t possible, injured workers and their physicians are challenged within the context of jurisdictionally approved treatment guidelines to improve care.

 

If executed consistently as part of a strategic plan to identify, intervene and remain involved until closure, the lessons learned from this type of settlement initiative will become imbedded into the claims management culture of the payer.

 

 

Identifying and Analyzing Claim Cost Drivers
Consider the case of an employer with longstanding open medical and legacy claims. Some of these claims may involve injured employees who are actively treating, even if it is just maintaining medications, while others may involve patients whose current medical condition is unknown. In either case, the employer’s first step is a file review that identifies claims in need of addressing for case settlement. The next step is the employer involving a strategic clinical partner to properly assess ongoing and future medical exposure, if any.

 

The best methods for analyzing future medical exposure are through a medical cost projection or a Medicare Set-Aside (MSA) if the claimant is a Medicare beneficiary or close to becoming one. An MSA has the added benefit of limiting medical care to treatment and medications that are Medicare-covered, thus potentially reducing future medical exposure for settlement. The goal of either method is to identify any red flags, such as:

 

  • Use of opioids, muscle relaxants and NSAIDS
  • Multiple prescribers of medications
  • Open-ended recommendations for surgery
  • Spinal cord stimulator recommendation
  • Prescription history that is inconsistent with the medical records
  • Most recent treatment date is so old that it leaves medical care open ended
  • Indication outside of medical records that injured employee continues to treat, but not through the workers’ compensation claim

 

The clinical partner needs to understand how the legal aspects of a claim (denied body parts and conditions and legal determinations) impact the assessment of future medical care and to be able to work effectively with defense counsel to limit ongoing and future medical care. Once the clinical partner projects future medical care and identifies red flags, the partner and employer should separate the claims into those that can immediately move to settlement negotiation, those that could settle after clinical or legal intervention, and those that are unlikely to benefit from intervention and thus cannot settle.

 

 

Appropriate Clinical Interventions
One size does not fit all when it comes to the right intervention to impact the medical care on a claim. If old medical records indicate open-ended medical care, then the intervention plan may involve the clinical partner contacting the last treating physician to confirm there has been no medical care delivered since the last date of service. If there has been medical care, the partner may track down additional medical records and assess future medical care based upon those records.

 

If there is a significant medication spend, a physician peer review may be the most appropriate claim intervention. A physician peer review is conducted by a practicing physician who performs an in-depth analysis of an injured employee’s medication regimen, comparing it to evidence-based medical and pharmaceutical guidelines. The physician peer reviewer then contacts the treating physician and discusses the drug regimen and current guidelines and asks the treating physician to change the pharmacy treatment or the medical treatment plan. The clinical partner obtains the treating physician’s written agreement to change the course of medical treatment and drug regimen. The partner follows up with the physician to ensure that changes actually occur and secures copies of medical records documenting the changes prior to preparing a settlement document.

 

 

Claim Closure
Once changes to medical and pharmaceutical care take place, the clinical partner works with the employer or carrier to revise the initial projections of future medical care whether contained in a medical cost projection or an MSA. If the latter, the MSA should be submitted to the Centers for Medicare and Medicaid Services (CMS) for approval. A settlement team should be assembled to work with the adjuster or a manager to complete negotiations and finalize the settlement.

 

 

About Dan Anders
Daniel M. Anders, Esq., MSCC is the Chief Compliance Officer for Tower MSA Partners. A certified Medicare Set-Aside Consultant and attorney, he oversees the Medicare Secondary Payer (MSP) compliance program. Mr. Anders is responsible for ensuring the integrity and quality of the MSA program and other services and products and he provides education and consultation to Tower MSA clients on all aspects of MSP compliance.

 

Mr. Anders is the former Senior Vice-President of MSP Compliance for ExamWorks Clinical Solutions and he has extensive litigation experience from his prior position with the Chicago law firm of Wiedner & McAuliffe. He holds a Juris Doctor from Chicago-Kent College of Law and a Bachelor of Arts degree from Loyola University Chicago.

 

Contact Mr. Anders at 847.946.2880 or daniel.anders@towermsa.com

 

 

About Tower MSA Partners
Tower MSATower MSA Partners is a national provider of Medicare Secondary Payer services, including Section 111 Reporting and Conditional Payments along with Medicare Set-Aside preparation, submission and oversight. Its proprietary MSP Automation Technology Suite drives MSP compliance best practices and provides end-to-end visibility into each activity. Tower’s other services include pre-MSA Triage, physician peer reviews, MSA administration, medical cost projections, and life care plans. With more than 50 years combined experience in pharmacy, legal oversight and medical care, Tower proactively stages claims and works collaboratively with clients to identify issues and intervene to modify outcomes. Tower remains involved in the claims, through final resolution, MSA and/or other settlement. This model enables Tower’s clients to provide better care to injured workers, reduce claim and MSA costs, and obtain CMS acceptance of the MSA. For more information, visit www.towermsa.com and subscribe to Tower’s www.mspcomplianceblog.com.

CMS MSA Review Expansion to Liability Planned for 2018

We are not even a week into 2017, but already have news to share regarding Medicare’s planned expansion of its Workers’ Compensation MSA review process to liability in 2018. In its recently released Request for Proposal for the Workers Compensation Review Contractor (WCRC), the Centers for Medicare and Medicaid Services (CMS) includes an option allowing CMS to expand the responsibilities of the WCRC to review of Liability Medicare Set-Asides (LMSAs) and No-Fault Medicare Set-Asides (NFMSAs) effective July 1, 2018.

 

The CMS WCRC RFP Solicitation may be viewed here.

 

 

Background on CMS Review of MSAs

 

Since 2001 CMS has had in place an official voluntary review process for Worker’ Compensation Medicare Set-Asides (WCMSAs). A WCMSA, as CMS states, is a “financial agreement that allocates a portion of a workers’ compensation settlement to pay for future medical services related to the workers’ compensation injury.” The purpose of the review then is “to independently price the future Medicare-covered medical services costs related to the WC injury, illness, and/or disease and to price the future Medicare covered prescription drug expenses related to the WC injury, illness and/or disease thereby taking Medicare’s payment interests appropriately into account.”

 

These WCMSA reviews were initially handled by the CMS Regional Offices spread throughout the country, but eventually transitioned to a centralized WCRC in 2005 (The CMS Regional Offices must still approve the review recommendation of the WCRC before it is released to the WCMSA submitter). CMS’s RFP solicitation for the new WCRC contract indicates the contract is to be awarded by June 30, 2017 with a contract term running for five years from July 1, 2017 to June 30, 2022.

 

 

Expectations for Liability MSA Reviews

 

Presently, CMS allows its 10 Regional Offices to accept voluntary requests for review of LMSAs at each office’s discretion. Some Regional Offices have consistently refused to review any LMSAs while other offices agree to review based upon criteria that seemingly changes over time and bears no indication that it is indeed the official policy of CMS. It appears then that just as it did in 2005 when CMS took the responsibility away from the Regional Offices for reviewing WCMSAs, CMS is now considering centralizing the process of reviewing LMSAs with a contractor, leaving the Regional Offices to only approve of the contractor’s recommendations.

 

Some may recall CMS launched a prior initiative to establish a formal policy for consideration of future medicals in liability settlements when it issued an Advanced Notice of Proposed Rulemaking in 2012. This initial effort was ultimately withdrawn by CMS in 2014. CMS’s new initiative began with this June 9, 2016 notice on the CMS website:

 

The Centers for Medicare and Medicaid Services (CMS) is considering expanding its voluntary Medicare Set-Aside Arrangements (MSA) amount review process to include the review of proposed liability insurance (including self-insurance) and no-fault insurance MSA amounts. CMS plans to work closely with the stakeholder community to identify how best to implement this potential expansion. CMS will provide future announcements of the proposal and expects to schedule town hall meetings later this year. Please continue to monitor CMS.gov for additional updates.

 

No town hall meetings were scheduled in 2016, however, based upon this RFP indicating LMSA reviews will not begin until at least July 1, 2018, CMS has given itself 18 months to develop and implement a formal LMSA review policy. In terms of how many liability settlements such a review process would impact, CMS seems uncertain. A Statement of Work attached to the RFP indicates “reviews could represent as much as 11,000 additional cases (based on all FY2015 NGHP demands), or as little as 800 additional cases annually, depending upon industry response.”

 

 

Tower MSA Takeaways

 

Over the past 15 years, starting with the formalized review of WCMSAs, continuing with the implementation of Section 111 Mandatory Insurer Reporting and recent stepped up efforts at denying injury-related medical care and recovery of conditional payments for medical care related to workers’ compensation, liability and no-fault claims, CMS has expanded its enforcement under the Medicare Secondary Payer Act. It is not surprising then that CMS’s next objective is formalizing a voluntary review process for LMSAs.

 

It has been our experience that when CMS does implement new policy and procedures it does take a deliberative approach evidenced by the at least 18-month timeframe signaled with this RFP to expand the MSA review process to liability and no-fault. Our expectation then is over the next 18 months or longer, CMS will provide additional announcements concerning the rules and procedures around expansion of the review process.

 

Tower MSA will be involved in these discussions and will keep you abreast of relevant developments. In the interim, there remain important obligations of parties to liability settlements and no-fault claims under the Medicare Secondary Payer Act. Rest assured that you can rely upon Tower MSA’s team of MSP compliance experts for consultation and expert guidance in liability and no-fault matters.

 

 

 

Author Dan Anders, Chief Compliance Officer, Tower MSA Partners. Dan oversees the Medicare Secondary Payer (MSP) compliance program. In this position, he is responsible for ensuring the integrity and quality of the MSA program and other MSP compliance services and products. Based upon his more than a decade of experience in working with employers, insurers, TPAs, attorneys and claimants, Dan provides education and consultation to Tower MSA clients on all aspects of MSP compliance. Contact: (847) 946-2880 or daniel.anders@towermsa.com

Christmas Miracles Can Happen in Workers’ Compensation

For those of us who deal with MSAs, it’s all too common to see claims at settlement time that started out as basic and simple, then spiraled downward as a result of bad prescribing habits, increased drug use and opioid addiction.  We hope for a different ending, but can  miracles really happen?

 

 

Background

 

In late 2015, Tower completed a pharmacy project for a small employer in California.  In the course of the project, drug triggers were identified, physicians were contacted and claimants were challenged to settle or make changes in treatment.  As you might imagine, many of the physicians fought the request for change.  But through perseverance, and working in tandem with the client, we pushed forward.

 

 

The Story as Shared by our Client

 

Dear Hany,

 

A few weeks ago, I was looking over the  case for one of the California claimants and wanted to share the amazing results we have achieved with this gentleman.

 

This case involved a 26 year old man at time of injury. He sustained a minor back injury but was taking Hydrocodone, Testosterone, Celecoxib, Lyrica, Nortriptyline, Methocarbamol, and FENTANYL.  With the recommendations and assistance from the Tower MSA Partners team, as well as support from his wife, we were able to get him into a new treating physician who agreed with our goal. He was weaned off of the Fentanyl, Methocarbamol, testosterone, hydrocodone, and Celecoxib. He has even started an exercise program.  He is now both proud and happy to report how well he is doing.

 

The injured worker is now 51 years old and he sadly notes that he missed out on 25 years of his life and his children’s lives because he was so “drugged”.   On a positive note, however, his new treating physician has been wonderful to work with and we see only good things for this claimant.

 

On the financial side we have now realized a reduction in the monthly Rx spend from $1,200 per month down to $600.  The injured worker is now only taking Nortriptyline, Lyrica and Celebrex and we expect to reduce reserves next year and approach him for a settlement in June, 2018.  None of this would have been possible if not for the Rx project and your team’s expertise, guidance and follow up assistance.

 

While we have had great success with many of the claims that we partnered on, this particular claim was really about improving his quality of life.  So please share my THANK YOU and gratitude with your team. Let them know that what they do can save a life and that is priceless.

 

 

It’s True….Miracles Can Happen in Workers’ Compensation

 

What a wonderful way to end the day and begin our holiday celebrations!

 

From all of us at Tower MSA Partners, our best wishes for a wonderful holiday, and a safe and prosperous 2017!

 

 

 

Author Rita Wilson, CEO, Tower MSA Partners, LLC. Rita oversees all business development, sales, marketing and operational activities, IT systems development, and identifies new product offerings in support of Medicare Secondary Payer Compliance. Prior to co-launching Tower MSA Partners in 2011, she founded and ran Select MRI, LLC, a diagnostic company, and Speedy Re-employment and Medicare Set Asides, an MSP compliance company. Previously, Wilson built out the operational and technology model for another startup, DirectCompRx, Inc., a subsidiary of Fiserv, Inc., ultimately becoming its CEO. Wilson is a Board Member for the National Association of Medicare Set Aside Professionals (NAMSAP). http://towermsa.com

Use Non-Therapeutic Pharmacy Changes to Reduce Your MSA Costs

Prescription drug costs represent both a source of national attention and a major cost driver of workers’ compensation claims dollars.  This trend will only continue.  Failure to use creative ideas to reduce the pharmacy portion of a claim can impact the bottom line and efficiency of your program.  One such creative solution all claims management teams should seek is service providers that identify non-therapeutic pharmacy changes that can yield significant MSA savings.  This is especially the case when your claim has a long tail medical treatment plan and includes a Medicare Set-aside.

 

 

Pharmacy Costs and Work Comp

 

A September 2016 NCCI research brief states “for every $100 paid for medical services provided to workers injured…$17 will be paid for prescription drugs.” They continue to state…”the prescription drugs portion of medical costs increases rapidly as claims age. For every $100 of medical services paid on claims older than 10 years, approximately $45 to $50 will be for prescription drugs.”

 

 

Non-Therapeutic Pharmacy Changes

 

The rapid increase in the prescription drug portion of medical costs in aging claims makes review of the pharmacy treatment plan compounded in importance when creating a Medicare Set-Aside for future medical costs.

 

Non-therapeutic pharmacy changes include:

 

  • Switching treatment from a brand name drug to generic.
  • Confirming discontinuation of a prescribed drug when the medical records are ambiguous
  • Requesting that the physician consider moving from a prescribed drug to over-the-counter.

 

 

Medicare Set-asides: Case Study – $774,583 Savings

 

Step 1: MSA Triage

 

  • Injury:
    • Struck by Lighting: Electric shock, difficulty sleeping, pain, depression, seizure activity

 

  • Prescription & Treatment Plan
    • hydrocodone/apap, baclofen, Topamax, duloxetine, Keppra, naproxen, and clonazapem, sleep apnea equipment

 

  • Original Projected MSA Cost 
    • $1,416,513 with brand new drugs and sleep apnea equipment

 

 
Step 2: Identify & Execute Intervention Strategy

 

  • Original Projected MSA Cost
    • $1,416,513 with brand new drugs and sleep apnea equipment

 

  • Non-Therapeutic Physician Follow Up Strategy
    • Identified opportunity to switch to generic, facilitated communication with physician, employee, and attorney to execute switch

 

  • Savings Realized
    • Future medical reduced from $1.4m to $641,930 by substituting generic; accepted by CMS and saved $774,583.*


*case study provided by Tower MSA Partners

 

The main driver in this MSA allocation was the cost of the brand name prescription drugs Topamax and Keppra.  In the above example, the MSA provider identified the opportunity for savings, facilitated the successful switch to generic drugs among all stakeholders and obtained the written evidence of the change in treatment necessary to secure CMS approval. The result was a $774,583 MSA savings that was accepted by CMS. It is important to note that communication and coordination among all parties allowed the switch to occur and the savings to be realized.

 

 

 

Review Non-Therapeutic Pharmacy Changes – Fees

 

The opportunity to realize dramatic savings without altering the clinical outcome for the patient warrants that non-therapeutic physician changes should be reviewed as a standard part of every MSA case file.

 

When evaluating your MSA vendor, ask the question if this service is included in the standard fee, or if it’s an additional charge? A vendor that provides the service at an additional charge will not utilize it as often and will realize significantly less savings than one in which it’s included in the standard fee.

 

 

Conclusions

 

Medical treatment and prescription drugs will continue to be a driver in the cost of all workers’ compensation claims.  Alterations in prescriptions via non-therapeutic pharmacy changes can mean savings for the parties, as well as other benefits in workers’ compensation claims. Opportunities for these changes should be reviewed on every MSA case file.

 

 

 

For additional information on workers’ compensation cost containment best practices, register as a guest for our next live stream training.

 

Author Michael Stack, Principal, COMPClub, Amaxx LLC. He is an expert in workers compensation cost containment systems and helps employers reduce their work comp costs by 20% to 50%.  He works as a consultant to large and mid-market clients, is co-author of Your Ultimate Guide To Mastering Workers Comp Costs, a comprehensive step-by-step manual of cost containment strategies based on hands-on field experience, and is founder of COMPClub, an exclusive member training program on workers compensation cost containment best practices. Through these platforms he is in the trenches on a working together with clients to implement and define best practices, which allows him to continuously be at the forefront of innovation and thought leadership in workers’ compensation cost containment.

Contact: mstack@reduceyourworkerscomp.com.

Workers’ Comp Roundup Blog: http://blog.reduceyourworkerscomp.com/

 

 

©2016 Amaxx LLC. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

Using Evidence Based Medicine In The MSA Review Process

RitaWilson

Rita Wilson, CEO, Tower MSA Partners

Rita Wilson, CEO, Tower MSA Partners

… on using evidence based medicine in the MSA review process

 

While CMS includes evidenced based medicine in its MSA evaluation resources, it does not require treatment to line up with science in order to be approved and allocated.  Consequently, many MSAs allocate for inappropriate medical procedures and pharmacy regimens that threaten patient safety.

 

Claims should be staged to identify treatment issues and cost drivers prior to preparing an MSA.  A proper pre-MSA Triage compares six months of medical records to clinical guidelines and this process frequently identifies recommended procedures or surgeries that have not occurred – and may never be needed.  To avoid funding procedures that will never take place, the next step is to contact treating physicians to clarify recommendations and make sure the medical records reflect ensuing changes.

 

Triage should also detect inappropriate pharmacy regimens that pose risks to patient safety and drive up settlement costs.  Often, injured employees are taking opioids, benzodiazepines and other drugs deemed inappropriate for their conditions by evidence-based guidelines.  Off-label use of certain drugs, like Lyrica, is another issue because Medicare will not pay for off-label use of certain drugs.  Sometimes there are prescriptions that have never been filled.  If not addressed, CMS will require their costs to be allocated in the MSA.  A best practice MSA provider will work with treating physicians to discontinue inappropriate medications, monitor tapering and secure the documentation CMS requires to allocate for the updated pharmacy program.

 

Applying EBM to claims is an extra step in the settlement, but well worth the time.  It protects patient safety by making sure treatment is sound and reduces costs by removing drugs and procedures that fall outside science.  It’s the right thing for the patient and the payer.

 

 


Using Evidence Based Medicine In The MSA Review Process

 

The concept of future medicals and Medicare Secondary Payer compliance is a challenging component of any workers’ compensation claim management team seeking to reduce costs in an ethical manner.  The voluntary Medicare Set-aside review process established by the Centers for Medicare and Medicaid Services (CMS) compounds this problem.  Use of Evidence Based Medicine (EBM) is one method that concerned parties can use to challenge CMS polices and provide a consistent result that meets the needs of workers’ compensation programs.

 

 

Understanding the Voluntary MSA Review Process

 

CMS started to provide guidance to parties regarding the workers’ compensation Medicare Set-aside review process in 2001.  This took the form of policy memoranda that was sometimes contradictory and confusing.  In an effort to streamline the process and make it more understandable, CMS changed course and consolidated this information into the Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) Reference Guide.

 

CMS will review a proposed WCMSA amount when the following workload review thresholds are met:

 

  • The claimant is a Medicare beneficiary and the total settlement amount is greater than $25,000.00; or

 

  • The claimant has a reasonable expectation of Medicare enrollment within 30 months of the settlement date and the anticipated total settlement amount for future medical expenses and disability/lost wages over the life or duration of the settlement agreement is expected to be greater than $250,000.00.

 

Consistent with federal regulation interpreting the Medicare Secondary Payer Act, CMS cautions parties that they must still consider Medicare’s interests even if a settlement does not meet the specified voluntary workload review thresholds.

 

 

Understanding CMS Policy Concerning Future Medicals

 

CMS does consider every workers’ compensation case in a proverbial vacuum.  For instance, “counter-highers” concerning the MSA allocation often arise in the following situations that most interested stakeholders consider unreasonable:

 

  • Degenerative changes that naturally occur resulting in prolonged medical care and treatment for a work injury that arguably only aggravates, but does not accelerate the an underlying condition. This prolonged care CMS seeks reimbursement for is often the result of the natural aging processes or prior non-work related injuries that sometimes require surgical intervention and costly prescription drug use;

 

  • The ongoing and sometimes excessive use of prescription pain medications. This is especially the case when it comes to opioid-based prescription medications, which significantly spike the cost of workers’ compensation claims.  These prescription medications can only be effective when used for acute pain relief and not long-term maintenance care; and

 

  • Issues raised in independent medical examination reports regarding the reasonableness and necessity of future medical care and treatment. Although these reports are prepared at the request of the employer/insurer, doctors performing these examinations have adequate foundation for issuing their expert opinions within a reasonable degree of medical certainty in a legal or administrative hearing.  CMS policy does not recognize the validity of these reports in the WCMSA review/approval process.

 

 

Using Evidence Based Medicine to Counter CMS Objections

 

EBM is a recognized approach within the practice of medicine that seeks to optimize the results in patient care via medical evidence based on research and design.  In the case of questions concerning the use of opioid-based prescription medications, this process is used to demonstrate the effectiveness of a certain treatment regimen and denote when the continued use losses it benefits.

 

Using EBM to stage the claim for submission and approval by CMS in the Medicare set-aside process does require work, but the payoff is significant.  The process includes utilization of medical records, scientifically supported medical research and an evaluation of trends to demonstrate the best course of future action for an injured worker in an effort to modify treatment.  It also includes a review of possible treatment modalities that discourage prescription drug abuse and deliver savings the interested stakeholders and an acceptable level of care to the injured party.  The use of medical experts to challenge inappropriate treatment, and the process of maintaining oversight over the claim until the CMS accepted evidence is obtained to demonstrate drug regimen can be time consuming, but the result is long-term savings and a CMS approved MSA that concurs with EBM guidance.

 

 

Conclusions

 

The challenges of the workers’ compensation system require members of the claim management team to be proactive.  One area includes the use of EBM to challenge CMS orthodoxy when it comes to costly future medical projections, which often include excessive use of dangerous opioid-based prescription drugs.  While costly, the use of EBM can reduce the threat posed by legacy claims.

 

 

Author Michael Stack, Principal, COMPClub, Amaxx LLC. He is an expert in workers compensation cost containment systems and helps employers reduce their work comp costs by 20% to 50%.  He works as a consultant to large and mid-market clients, is co-author of Your Ultimate Guide To Mastering Workers Comp Costs, a comprehensive step-by-step manual of cost containment strategies based on hands-on field experience, and is founder of COMPClub, an exclusive member training program on workers compensation cost containment best practices. Through these platforms he is in the trenches on a working together with clients to implement and define best practices, which allows him to continuously be at the forefront of innovation and thought leadership in workers’ compensation cost containment. Contact: mstack@reduceyourworkerscomp.com.

 

 

©2016 Amaxx LLC. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

Changing Hearts and Minds to Win the Battle Against Prescription Drug Abuse

The expansion of Medicare to include a prescription drug benefit has had varied results on the workers’ compensation system and compliance with the Medicare Secondary Payer Act.  While this expansion has assisted countless Medicare beneficiaries receive their necessary prescription drugs as an affordable price, it has come at a cost.  This is a setback in compounding the prescription drug epidemic and increasing the “cost” of a Medicare Set-aside allocation.

 

 

Prescription Drug Expansion in Medicare

 

The creation of the Medicare program in July 1965 allowed disabled and older Americans to receive affordable health care coverage.  While this was heralded as a step forward, the program lacked the ability of Medicare beneficiaries to receive an affordable prescription drug benefit.  Congress addressed this issue in 2006, when they expanded the Medicare program to include a Part D prescription drug benefit.  Under this new program, anyone who has coverage under Medicare Parts A or B (Traditional Medicare) is eligible for Part D.  This includes those receiving coverage under a Medicare Advantage Plan, which typically have Part D coverage as part of the plan.

 

Following the passages of the Part D program, CMS was quick to provide guidance on how Medicare Set-aside allocations should address this matter.  The result was a dramatic increase in the cost of such allocations given the increasing use of prescription drugs in injury treatment regimens.  Significant costs can also be incurred if the injured employee is using opioid-based prescription drugs.

 

 

Medicare Part D Adding to the Drug Epidemic

 

Prescription drugs abuse is dramatically increasing the cost of workers’ compensation claims.  An example of this impact is as follows:

 

  • $13,000: Average cost of a claim without opioids;
  • $39,000: Average cost of a claim with Percocet; and
  • $117,000: Average cost of a claim with long-acting OxyContin.

 

Under Part D guidelines, plan sponsors may in fact be fueling the prescription drug epidemic.  According to industry sources, it has been recommended that sponsors of Part D plans change dispensing guidelines in their plans for beneficiaries taking a 120 mg morphine equivalent daily dose.  This includes those beneficiaries who are using prescriptions for opioid-based prescriptions for more than 90 days.  Other factors that are leading to deadly results include people who are receiving their prescription medications from multiple prescribers and pharmacies.  The prolonged use of these prescription medications is not only expensive, but can result in addiction and negative health consequences.

 

In highlighting this problem, the National Alliance of Medicare Set-Aside Professionals (NAMAP) have become more engaged in educating stakeholders and advocating for change.  According to a recent statement from NAMSAP asked, “why do workers’ compensation MSA approvals often include future prescription allocations with Morphine Equivalent Dosages in excess of 120, 200, or even 500 per day, over the beneficiary’s full life expectancy?  And what message does a workers’ compensation MSA supporting these high opioid dosages over a patient’s entire life expectancy send to the addicted patient?”

 

 

Combatting the Epidemic: Being an Advocate for Change

 

No single law or rule that will end the opioid-based prescription drug problem in America and reduce workers’ compensation program costs.  Action instead must come from a demand for change in how we address the use of these prescription drugs within the system—to change the hearts and minds of policymakers.  It includes advocacy with the state and federal governments in how they view this matter when it comes to providing medical care and treatment to injured persons.

 

One important action comes in the form of allocations for opioid-based prescription medications in Medicare Set-aside allocations.  Under the current CMS rationale, medical care and treatment, including pharmacy related issues, must cover the life expectancy of the claimant.  This philosophy is not practical for a claimant using OxyContin or other related prescriptions.  By using Evidence Based Medicine (EBM) techniques, interested stakeholders must highlight the dangers of long-term opioid-based drug use and instead, promote their use for shorter periods.

 

 

Author Michael Stack, Principal, COMPClub, Amaxx LLC. He is an expert in workers compensation cost containment systems and helps employers reduce their work comp costs by 20% to 50%.  He works as a consultant to large and mid-market clients, is co-author of Your Ultimate Guide To Mastering Workers Comp Costs, a comprehensive step-by-step manual of cost containment strategies based on hands-on field experience, and is founder of COMPClub, an exclusive member training program on workers compensation cost containment best practices. Through these platforms he is in the trenches on a working together with clients to implement and define best practices, which allows him to continuously be at the forefront of innovation and thought leadership in workers’ compensation cost containment. Contact: mstack@reduceyourworkerscomp.com.

 

 

©2016 Amaxx LLC. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

Professional Development Resource

Learn How to Reduce Workers Comp Costs 20% to 50%"Workers Compensation Management Program: Reduce Costs 20% to 50%"
Lower your workers compensation expense by using the
guidebook from Advisen and the Workers Comp Resource Center.
Perfect for promotional distribution by brokers and agents!
Learn More

Please don't print this Website

Unnecessary printing not only means unnecessary cost of paper and inks, but also avoidable environmental impact on producing and shipping these supplies. Reducing printing can make a small but a significant impact.

Instead use the PDF download option, provided on the page you tried to print.

Powered by "Unprintable Blog" for Wordpress - www.greencp.de