Made Whole Fork

Medicare Conditional Payment Priority

Medicare conditional payments generally take priority under the Medicare Secondary Payer Act. Medicare expects repayment from third-party settlements but may reduce claims for procurement costs.

Last updated: August 27, 2026

Medicare Secondary Payer Act

The Medicare Secondary Payer Act makes Medicare a secondary payer when another payer (such as liability insurance or workers' compensation) is primary. When Medicare makes conditional payments because the primary payer has not yet paid, Medicare has a statutory right to recover those payments from any third-party settlement, judgment, or award.

FeatureRuleNotes
Repayment ObligationMandatoryBeneficiary and attorney must repay Medicare conditional payments
Made Whole DoctrineDoes not applyMedicare expects repayment even if beneficiary not made whole
Procurement Cost ReductionMay applyMedicare may reduce claim for attorney fees and costs
Priority vs. Private PlansHighFederal law generally takes priority over ERISA and state lien law

Priority Over Other Claimants

Medicare's priority is based on federal law, which generally preempts state lien statutes and takes priority over private health plan subrogation claims. Even self-funded ERISA plans, which preempt state law, do not preempt Medicare's federal priority under the Medicare Secondary Payer Act.

Competing ClaimantPriorityReasoning
Hospital Statutory LienMedicare firstFederal law preempts state lien statute
Self-Funded ERISA PlanMedicare firstMedicare Secondary Payer Act takes priority over ERISA plan claims
Fully Insured PlanMedicare firstFederal law preempts state insurance law
Medicaid LienDepends on coordination rulesFederal and state law determine which program paid first

Procurement Cost Reductions

Medicare reduces its conditional payment recovery to account for procurement costs—the attorney fees and litigation expenses incurred to obtain the settlement. Under 42 CFR 411.37, the reduction is calculated using a mandatory formula: (1) determine the ratio of procurement costs to the total settlement, (2) apply that ratio to the Medicare payment to calculate Medicare's share of procurement costs, (3) subtract Medicare's share of procurement costs from the Medicare payment. This is a required calculation, not a discretionary reduction.

Reporting and Compliance

Settlement parties must report third-party settlements to Medicare within required timeframes. The beneficiary or their attorney must notify Medicare of the settlement and request a demand letter showing the conditional payment amount. Failure to report can result in penalties, and failure to repay Medicare can result in liability for the beneficiary, their attorney, and the liability insurer.

Compromise and Waiver

Medicare has authority to compromise or waive its recovery claim in certain circumstances, such as when the recovery cost would exceed the amount collected, or when repayment would cause financial hardship. Compromise requests are evaluated on a case-by-case basis and must be submitted to the Medicare Secondary Payer Recovery Contractor.

Does Medicare have to be repaid from a personal injury settlement?

Yes, when Medicare makes conditional payments as a secondary payer. The Medicare Secondary Payer Act requires repayment from any third-party recovery. Medicare does not recognize the made whole doctrine, but may reduce its claim based on procurement costs such as attorney fees and litigation expenses.

Can Medicare take priority over an ERISA health plan's subrogation claim?

Yes. Medicare's priority is based on federal law (Medicare Secondary Payer Act), which generally takes priority over private plan claims. Even self-funded ERISA plans, which preempt state law, do not preempt Medicare's federal priority.