CMS Prescription Drug Set-Aside Guidance for Submitters

Since the publication of the April 3, 2009 CMS policy memorandum announcing prescription drug reviews, which becomes effective June 1, 2009, submitters of Workers’ Compensation Medicare Set-aside Arrangements (“WCMSAs”) have raised several questions concerning how certain situations will be treated by CMS and the Workers’ Compensation Review Contractor (“WCRC”).