Future medical allocation
All injury-related future medical care and prescription drugs are identified from the medical and pharmacy history, projected over the claimant's life expectancy, and priced against CMS fee schedules and drug pricing.
The most defensible MSA allocation and Section 111 report a WC payer can file.
The Compliance Engine assembles a documentation-complete Medicare Set-Aside allocation and matching Section 111 report — every statutory element, every required medical record extraction, the CMS fee schedule pricing, the life-expectancy projection, and the mandatory reporting fields — checked against the Medicare Secondary Payer Act and CMS guidance before a certified reviewer releases it.
Every element of the Medicare Secondary Payer ActCMS fee schedule & drug pricing, gate-checkedMedical record extraction · pharmacy history · life expectancyCertified MSA/clinical reviewer release on every file5-business-day SLA
Why allocations fail
A single missing element can trigger False Claims Act exposure.
A workers' compensation settlement with a Medicare beneficiary now requires a defensible Medicare Set-Aside allocation and mandatory Section 111 reporting — even below the $25k CMS review threshold, even for $0 allocations. Miss a future medical item, misprice a drug against the correct fee schedule, fail to report the MSA amount or funding type, and Medicare can refuse to recognize the settlement or pursue post-settlement recovery.
Most payers run this by hand, from memory, once or twice a year. The Medicare Secondary Payer Act has not been read end-to-end since the last time it mattered. That is exactly where completeness gaps hide.
The Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every file.
1 of 5
missing allocation elements is enough to jeopardize a settlement
The benchmark
Measured against the letter of the MSP Act and CMS guidance — subsection by subsection.
We do not summarize the law and hope. Every allocation and report is scored against a versioned rule pack tied to the exact text of the Medicare Secondary Payer Act and CMS WCMSA Reference Guide. These are the provisions each file is held to.
Section 111 mandatory reporting
Every settlement with a Medicare beneficiary is reported to CMS with the MSA amount, period, funding type, initial and annual deposit, case control number, and professional-administrator EIN — all fields present, or the report does not release.
CMS review threshold & $0 allocations
For settlements at or above the CMS review threshold ($25k current beneficiary; $250k reasonable expectation), the allocation is submitted for CMS approval. For $0 allocations, a defensible self-determination is documented with supporting evidence.
False Claims Act avoidance
Every allocation and report is structured to avoid knowingly presenting a false claim — the allocation is supported by medical records, pricing is verified, and reporting fields are accurate.
Life expectancy & projection methodology
Life expectancy is determined using CMS-recognized mortality tables and adjusted for the claimant's comorbidities. Future treatment frequency and duration are projected based on standard medical guidelines.
Medicare's right to recover
The allocation ensures Medicare is not billed for injury-related care that should be paid by the set-aside. The report documents the funding mechanism and administration to prevent post-settlement recovery.
How a file is built
Intake to certified reviewer release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A certified MSA/clinical reviewer signs every release. That order is never reversed.
01
Delinquency Gap Scan
Upload the settlement details, medical records, and pharmacy history. We return a free completeness read: which statutory elements and pricing data you already have, and which are missing.
02
Medical record extraction & pricing
As your authorized clerical agent, we retrieve and de-duplicate medical records, extract diagnoses and treatment history, isolate injury-related care, and price each line against CMS fee schedules and drug pricing.
03
Grounded drafting
The allocation report and Section 111 fields are drafted from your validated data and the MSP rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
All future medical items are reconciled to the medical record; pricing matches CMS fee schedules; life expectancy is verified; Section 111 fields are complete; any failure blocks release.
05
Certified reviewer release
A certified MSA/clinical reviewer reviews the exception queue and signs the release. High-value or complex cases route to attorney review first.
06
Delivery
You receive the allocation report, Section 111 data file, evidence log, pricing workbook, and administration instructions — ready for the payer to file with CMS and fund the set-aside.
The bar we hold
Rigor you can measure.
100%
Certified reviewer-released
No file ships without a human signature.
5 days
Standard SLA
From complete intake to released allocation and report.
<1%
Critical-defect target
Tracked against a gold-standard allocation library.
3
Pricing sources
CMS fee schedule · Medicare drug pricing · life expectancy tables, every applicable file.
Why the Compliance Engine
Built to be the most thorough option a payer has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory element and pricing item accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.
In its lane, on purpose
We prepare documentation and run pricing as your clerical agent. We never give legal advice, determine settlement strategy, or act as a fiduciary.
Engagement
Flat fee, per released allocation and report. No contingency, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any settlement.
- A free Delinquency Gap Scan before you commit — see exactly what is missing.
- One flat fee per released MSA Allocation & Section 111 Report; disclosed pass-through pricing data fees.
- Optional fixed-fee attorney review for high-value or complex cases.
- Optional Professional Administration Add-on for ongoing account management and annual reporting.
FAQ
Questions, answered precisely.
Is the Compliance Engine a law firm?
No. The Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for high-value or complex cases.
Do you determine settlement strategy or act as a fiduciary?
Never. The Compliance Engine is not a fiduciary and does not determine settlement amounts or strategy. The payer remains responsible for all settlement decisions and for funding the set-aside.
What makes an allocation 'complete'?
Completeness is defined by the MSP Act and CMS guidance: all injury-related future medical care identified and priced, life expectancy projected, Section 111 fields populated, and pricing verified against CMS fee schedules. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a certified reviewer-released allocation and report. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released allocation and report, plus disclosed pass-through pricing data costs. No contingency and no percentage of any settlement amount.
See what's missing before it costs you a settlement.
Start with a free Delinquency Gap Scan. Send your settlement details, medical records, and pharmacy history and we'll return a completeness read against every element of the MSP Act and CMS guidance.
Documentation-completeness service · not legal advice · the payer files every report.