# ROADMAP — TopMVA skill library

**Updated 2026-07-17, alongside v0.2.0.**

v0.2.0 added verified authority to the five existing skills. It did not add skills.
The authority audit that produced v0.2.0 identified three gaps that no existing
skill covers, listed here so they are tracked rather than rediscovered.

---

## 1. Lien resolution — the highest-priority gap

**Currently distributed across nothing.** mva-case-evaluation models a gross-to-net
waterfall that runs `→ minus liens/subrogation →` and then stops. The single
highest dollar-per-hour work in a personal-injury file has no skill.

What it would carry (all verified — see `mo-authority.md` § 8):
- Missouri's **anti-subrogation default** — *Hays v. Missouri Highways &
  Transportation Commission*, 62 S.W.3d 538, 540 (Mo. App. W.D. 2001) — and the
  reframing it forces: the first question is not "how far down do we negotiate,"
  it is "does this entity have any right to be paid at all."
- **ERISA self-funded** — *US Airways v. McCutchen*, 569 U.S. 88 (2013);
  *Montanile v. Board of Trustees*, 577 U.S. 136 (2016) — and the plan-document
  request that decides both, 29 U.S.C. § 1024(b)(4), penalty at § 1132(c)(1)(B).
- **FEHBA** — *Coventry Health Care of Missouri, Inc. v. Nevils*, 581 U.S. 87
  (2017), reversing *Nevils*, 418 S.W.3d 451.
- **Medicare** — conditional payments, 42 C.F.R. § 411.24(g)–(i).
- **Medicaid / MO HealthNet** — *Gallardo v. Marstiller*, 596 U.S. 420 (2022).
- **Hospital and ambulance liens** — § 430.225.3 vs. § 430.250 (two 50% rules on
  two different denominators), § 190.250.
- The negotiation letters themselves, which no current skill drafts.

**Blockers:** §§ 430.230, 430.240, § 537.675 not pulled. Missouri's made-whole
authority within the ERISA exception is unresearched.

## 2. UM/UIM coverage analysis

mva-case-evaluation now models the UIM offset but does not **read the policy**.

What it would carry:
- Anti-stacking — *Ritchie v. Allied Property & Casualty Insurance Co.*, 307
  S.W.3d 132 (Mo. banc 2009); *Floyd-Tunnell v. Shelter Mutual Insurance Co.*,
  439 S.W.3d 215 (Mo. banc 2014).
- Policy-construction canons that transfer directly to a UM endorsement:
  *Gulf Insurance Co. v. Noble Broadcast*, 936 S.W.2d 810, 814 (Mo. banc 1997)
  (contra proferentem); *Columbia Mutual Insurance Co. v. Epstein*, 239 S.W.3d 667
  (Mo. App. 2007) (the **insurer** bears the burden to prove an exclusion);
  *Standard Artificial Limb, Inc. v. Allianz Insurance Co.*, 895 S.W.2d 205, 209
  (Mo. App. 1995) (reasonable expectations).
- The household inventory mva-intake-summary now collects (vehicles, policies,
  resident relatives) exists to feed this skill. Right now it feeds nothing.

## 3. Settlement and disbursement

The library ends at the demand. Nothing covers closing the file.

What it would carry: release review; **§ 537.095** minor and wrongful-death court
approval (⛔ not pulled); the disbursement statement; the closing letter; and the
Medicare branch mva-case-evaluation now flags but cannot resolve — conditional
payments, the MSA question, and Section 111 reporting.

---

## Also tracked

- **A venue / jurisdiction module** for mva-case-evaluation. § 508.010 (⛔ not
  pulled, rewritten 2005), the nonresident-motorist long-arm provisions, and
  *Ford Motor Co. v. Montana Eighth Judicial District Court*, 592 U.S. 351 (2021)
  for the manufacturer-defendant crashworthiness case.
- **Missouri negligence per se elements** — ⛔ no case identified. Until one is,
  mva-demand-builder asserts the framework without authority, which is the same
  defect v0.2.0 was built to fix. This is the most embarrassing open item.
- **The rules of the road** — §§ 304.012, 304.017, 304.351 ⛔ not pulled.

## Open items gating all of the above

See the ⛔ markers throughout `mo-authority.md`. Roughly two dozen. They are
published rather than quietly worked down, because a library whose promise is that
the skills refuse to invent facts should show what it does not know.