Undercoding and Its Role in $31.7 Billion Medicare Improper Payments

Introduction

Despite Medicare requiring accurate documentation and coding for decades, healthcare providers continue to undercode services at alarming rates. This white paper examines the undercoding crisis contributing to Medicare’s $31.7 billion annual improper payments: conservative coding practices, documentation burden, fear-based billing, lack of audit programs, and insufficient education that make accurate revenue capture difficult for organizations.

Key Takeaways

  • 42% of E/M claims were incorrectly coded in OIG studies
  • Undercoding creates compliance risks, not just revenue loss
  • Conservative coding to avoid audits can trigger CMS scrutiny
  • Documentation burden contributes to missed billing opportunities
  • Risk-adjusted models require accurate coding for reimbursement
  • Regular coding audits are essential for compliance programs
  • Updated E/M guidelines reduced the administrative burden since 2021

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