CMS Issues WCMSA Reference Guide Version 4.6, Adding Structured-Settlement Billing Guidance and Medicare Advantage Coordination Language
The July 13 update refines Appendix 5 correspondence templates and introduces explicit requirements for chronological bill payment from structured-settlement-funded Medicare Set-Aside accounts.
By the Work Comp Brief automated newsroomGrounded in cms.gov
Produced by Work Comp Brief’s automated editorial pipeline (AI agents) under human oversight, grounded in the primary source above. How we work.
The Centers for Medicare & Medicaid Services released Version 4.6 of the Workers' Compensation Medicare Set-Aside Arrangement (WCMSA) Reference Guide on July 13, 2026, according to the document published on CMS.gov. The release is the second WCMSA Reference Guide update in 2026; Version 4.5 was issued on April 13.
Version 4.6 does not restructure the core WCMSA approval process or alter submission thresholds. Its primary changes fall in three areas: updated correspondence templates in Appendix 5, new billing-order guidance for structured-settlement-funded MSA accounts, and clarified language on coordinating approved WCMSAs with Medicare Advantage (Part C) and Part D prescription-drug plans.
Appendix 5 template updates. Appendix 5 of the reference guide contains model letters CMS issues following a voluntary WCMSA submission. Version 4.6 revises language in the Approval Letter and the Notice of Settlement Received Letter contained in that appendix, and also reflects a fax-number update for documentation submissions.
Structured-settlement billing order. For MSA accounts funded by a structured settlement rather than a lump sum, Version 4.6 specifies that medical bills must be submitted and paid in the chronological order they are received. The instruction is directly tied to the review process operated by CMS's Benefits Coordination & Recovery Contractor (BCRC): when a self-administering claimant seeks to demonstrate that the MSA account has been temporarily or permanently exhausted, the BCRC uses the payment record to confirm that claim. Out-of-sequence bill payment disrupts that review and can delay or preclude a finding of exhaustion, leaving the claimant without Medicare coverage for otherwise-covered compensable conditions.
Medicare Advantage and Part D coordination. Version 4.6 also addresses the relationship between an approved WCMSA and a claimant's Medicare Advantage (Part C) or Part D prescription-drug plan. CMS notifies the claimant's Part C and Part D plans when a WCMSA is approved, but does not transmit the specific treatments or medications that the WCMSA covers rather than the plan. Those plans may contact the claimant or the MSA administrator to obtain that information. Version 4.6 further clarifies that parties administering a WCMSA are expected to notify the relevant Part C and Part D plans annually and whenever the treatment plan changes materially.
Work Comp Brief grounds every report in the official record. Read the primary document above.
Work Comp Brief is general market & regulatory information for insurance professionals — not legal, financial, actuarial, or coverage advice, and not a substitute for professional counsel or the official source.