CMS stopped reviewing $0 Medicare Set-Aside proposals on July 17, 2025, and 2026 is the first full year under the new rule. The government stamp of approval that defended $0 allocations is gone.
That does not lighten the obligation, it shifts where the obligation lives. The injured worker, the attorney, and the payer now carry the documentation burden directly. If CMS later concludes future medical was needed, there is no approval letter to point to.
Atlas Managed Care builds MSA work around that reality. Documentation that holds up under later scrutiny. Allocations grounded in the actual treatment record, not a template. A file a carrier can open three years from now and still trace the reasoning.
The government has stepped back from the review. That makes the work underneath it more important, not less.
Source: Brandon J Broderick analysis of CMS MSA enforcement (May 24, 2026); Tower MSA Partners MSP Compliance Blog
Source: Brandon J Broderick / Tower MSA Partners
Documentation that holds up three years later.
Atlas builds MSA work around post-CMS-review reality. Documentation grounded in the actual treatment record, not a template. A file a carrier can open three years from now and still trace the reasoning.
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