CMS Updates Amended Review Submission Criteria

by B. Smith

On January 21, 2025, CMS issued a separate alert noting the changes to the zero-dollar MSA review process (see our separate blog on this topic here), and also announcing changes to the timeframes for submission of Amended Reviews. Currently, an Amended Review can only be submitted to CMS if one year has passed since the approval of the WCMSA.

According to this new alert, effective April 7, 2025, Amended Review requests may be requested at any time after a WCMSA is approved.  This does not eliminate the other criteria for an Amended Review including the requirement to show a $10,000 or 10% change (whichever is greater) from the original WCMSA amount.  Also, the alert does not state whether WCMSAs that were approved prior to April 7, 2025, can be submitted for Amended Review if they do not meet the one-year requirement.  IMPAXX has reached out to CMS for clarification regarding the same.

For more questions regarding the above or for further information regarding our Zero Waiver Allocations and Amended Reviews, please contact our Settlement Consultant Team at [email protected].