Pre-Submission Code Validation

Validate codes before submission to prevent compliance issues:

Code Validity

Verify codes are valid for the service date and payment year.

Documentation Support

Confirm clinical documentation supports each submitted code.

Provider Qualification

Ensure diagnoses come from acceptable provider types.

Encounter Requirements

Verify face-to-face encounter requirements are met.

Audit Risk Indicators

Identify patterns that may trigger audit scrutiny:

  • Rapid RAF growth: Unusually fast increases in risk scores
  • High-value HCC concentration: Disproportionate coding of high-coefficient HCCs
  • One-way coding: Adding HCCs without corresponding deletions
  • Provider outliers: Providers with RAF patterns significantly above peers
  • Chart review discrepancies: High deletion rates in internal audits
Risk Alert: CMS uses predictive analytics to identify plans with suspicious coding patterns for RADV audit selection.

Common Compliance Gaps

Address these frequently identified compliance issues:

  • Missing MEAT: Conditions coded without Monitor, Evaluate, Assess, Treat documentation
  • Specificity mismatches: Code specificity not supported by documentation
  • Resolved conditions: Coding conditions that have been resolved
  • History code errors: Using active codes for historical conditions
  • Linkage failures: Symptoms coded without definitive diagnosis linkage
5-15% Typical deletion rate found in RADV audits across the industry

Reconciliation Against CMS Feedback

Use CMS feedback reports to validate and improve coding:

  • MAO-004 reports: Review accepted vs rejected HCCs
  • RAPS return files: Analyze rejection reasons and patterns
  • Encounter data feedback: Reconcile encounter submissions
  • Payment reconciliation: Compare expected vs actual RAF payments
Monthly

Ongoing Reconciliation

Regular comparison of submitted data against CMS acknowledgments and payment reports.

Annual

Final Reconciliation

Year-end validation against final CMS payment calculations and feedback.

Compliance Tools

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