The Centers for Medicare & Medicaid Services (CMS) has published a final rule that implements Medicare Secondary Payer (MSP) appeals provisions under the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act). Specifically, the rule addresses the right of appeal and a new multilevel appeal process for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation laws or plans when Medicare pursues an MSP recovery claim directly from the applicable plan. The regulations are effective on April 28, 2015; applicable plans are parties to initial determinations issued on or after April 28, 2015 where CMS pursues recovery directly from the plan. Throughout the final rule, CMS reiterates its authority to recover directly from an applicable plan regardless of any prior attempts to recover from the beneficiary or provider, underscoring the need to address MSP recovery in all personal injury settlements with Medicare beneficiaries.