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Series: Risk Adjustment Data - Sufficiency of Documentation Supporting Diagnoses

Announced on  | Last Modified on  | Series Number: W-00-24-35078

OBJECTIVE

Payments to Medicare Advantage organizations are risk adjusted on the basis of the health status of each beneficiary. Medicare Advantage organizations are required to submit risk adjustment data to Centers for Medicare & Medicaid Services in accordance with Centers for Medicare & Medicaid Services instructions (42 CFR § 422.310(b)), and inaccurate diagnoses may cause Centers for Medicare & Medicaid Services to pay Medicare Advantage organizations improper amounts (SSA §§ 1853(a)(1)(C) and (a)(3)). In general, Medicare Advantage organizations receive higher payments for sicker patients. Centers for Medicare & Medicaid Services estimates that 9.5 percent of payments to Medicare Advantage organizations are improper, mainly due to unsupported diagnoses submitted by Medicare Advantage organizations. Prior OIG reviews have shown that medical record documentation does not always support the diagnoses submitted to Centers for Medicare & Medicaid Services by Medicare Advantage organizations. We will review the medical record documentation to ensure that it supports the diagnoses that Medicare Advantage organizations submitted to Centers for Medicare & Medicaid Services for use in Centers for Medicare & Medicaid Services' risk score calculations and determine whether the diagnoses submitted complied with Federal requirements.

There are 3 projects in this series.

COMPLETED PROJECTS IN THIS SERIES (3)

Medicare Advantage Compliance Audit of Diagnosis Codes That EmblemHealth (Contract H3330) Submitted to CMS

Medicare Advantage Compliance Audit of Diagnosis Codes That MMM Healthcare, LLC, (Contract H4003) Submitted to CMS

Medicare Advantage Compliance Audit of Diagnosis Codes That Humana, Inc. (Contract H1036), Submitted to CMS

TIMELINE

  • July 15, 2016
    Series Number W-00-24-35078 Assigned
  • July 15, 2016
    Project Announced

    Medicare Advantage Compliance Audit of Diagnosis Codes That Humana, Inc. (Contract H1036), Submitted to CMS - A-07-16-01165

  • March 12, 2018
    Project Announced

    Medicare Advantage Compliance Audit of Diagnosis Codes That EmblemHealth (Contract H3330) Submitted to CMS - A-06-18-02001

  • December 12, 2019
    Project Announced

    Medicare Advantage Compliance Audit of Diagnosis Codes That MMM Healthcare, LLC, (Contract H4003) Submitted to CMS - A-04-20-07090

  • April 19, 2021
    Project Complete - A-07-16-01165

    Medicare Advantage Compliance Audit of Diagnosis Codes That Humana, Inc. (Contract H1036), Submitted to CMS has been marked as complete. This audit resulted in 2 recommendations.

  • August 13, 2024
    Project Complete - A-04-20-07090

    Medicare Advantage Compliance Audit of Diagnosis Codes That MMM Healthcare, LLC, (Contract H4003) Submitted to CMS has been marked as complete. This audit resulted in 2 recommendations.

  • September 24, 2024
    Project Complete - A-06-18-02001

    Medicare Advantage Compliance Audit of Diagnosis Codes That EmblemHealth (Contract H3330) Submitted to CMS has been marked as complete. This audit resulted in 2 recommendations.

  • September 24, 2024
    Series Complete

    Risk Adjustment Data - Sufficiency of Documentation Supporting Diagnoses has been marked as complete.

3 REPORT PUBLISHED

24-A-04-095.01 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that MMM Healthcare, LLC, refund to the Federal Government the $165,312 of net overpayments.

24-A-04-095.02 to CMS - Open Unimplemented
Update expected on 03/30/2026
We recommend that MMM Healthcare, LLC, continue to improve its policies and procedures to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments.

View in Recommendation Tracker

24-A-06-109.01 to CMS - Open Unimplemented
Update expected on 03/24/2026
We recommend that EmblemHealth refund to the Federal Government the $551,917 of net overpayments.

24-A-06-109.02 to CMS - Open Unimplemented
Update expected on 03/24/2026
We recommend that EmblemHealth continue to ensure that its policies and procedures have been adequately designed and implemented to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments.

View in Recommendation Tracker

21-A-07-081.01 to CMS - Open Unimplemented
Update expected on 04/01/2026
We recommend that Humana, Inc. refund to the Federal Government the $197,720,651 of net overpayments.

21-A-07-081.02 to CMS - Open Unimplemented
Update expected on 04/01/2026
We recommend that Humana, Inc. enhance its policies and procedures to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments.

View in Recommendation Tracker

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