Learn From Past Comparative Billing Reports
- By Annie Barnaby
- In Billing
- June 1, 2023
- No Comments

Billing and prescribing activities prone to improper Medicare Part B payments.
The Centers for Medicare & Medicaid Services (CMS) initiated the Comparative Billing Report (CBR) program in 2010 to evaluate claims submission data, develop provider education, and raise awareness of peer-to-peer billing patterns. CBRs are unique to a specific provider and can be used as a free educational resource and tool for possible billing improvements. Even the most compliant billing process can benefit from this sort of analysis. In this article, we’ll look at two completed CBRs for 2022.
Recent CBR Releases
CBR topics for 2022 included billing for certain services in chiropractic, podiatry, allergy and immunology, ambulance, laboratory, and ophthalmology.
Immunosuppressive Drugs
Vulnerability:
Immunosuppressive drugs carry an improper payment rate of 23.7 percent, which represents $63,087,097 in possible improper payments. A 50.6 percent improper payment rate is attributed to insufficient documentation and a 12.9 percent improper payment rate is attributed to medical necessity errors.
Metrics:
1. Percentage of immunosuppressive drug claim lines submitted, per code
2. Percentage of immunosuppressive drug claim lines submitted with modifier KX
After reviewing and researching the improper payment rate, this CBR was created to analyze the possible threat to the Medicare Trust Fund associated with immunosuppressive drugs. The expectation is that rendering providers of immunosuppressive drugs will maintain proper coding documentation procedures and confirm appropriate use of modifier KX.
Bronchodilator Nebulizer Medications
Vulnerability:
Nebulizers and related drugs carry an improper payment rate of 13.5 percent, which represents $111,637,609 in possible improper payments for Medicare Part B claims. A 66.2 percent improper payment rate is attributed to insufficient documentation and a 12.9 percent improper payment rate is attributed to medical necessity errors.
Metrics:
1. Average allowed units, per beneficiary, by category
2. Percent of paid claims for bronchodilator nebulizer medications submitted for J7620
After reviewing and researching the improper payment rate, this CBR was created to analyze the possible threat to the Medicare Trust Fund associated with bronchodilator nebulizer medications.
Initial Nursing Facility E/M Visits
Vulnerability:
Nursing home visits hold an improper payment rate of 14.1 percent, which represents $341,892,648 in possible improper payments for Medicare Part B claims. A 37.1 percent improper payment rate is attributed to insufficient documentation and a 54.9 percent improper payment rate is attributed to incorrect coding.
Metrics:
1. Average weighted services billed, per day
2. Percentage of beneficiaries with more than one allowed service
3. Percentage of total Medicare Part B allowed amount submitted for initial nursing facility evaluation and management (E/M) visits
To learn more: Read the December 2022 article, How to Use Comparative Billing Reports as an Educational Tool.
Add CBRs to Your Compliance Arsenal
Compliance is constantly evolving and expanding to every area of patient care administration. More than ever, correct billing and coding plays a key role in claim submission and in the protection of the Medicare Trust Fund. CBRs support compliance and education by raising awareness and offering tailored knowledge for recipients. All providers and support staff can take advantage of the wealth of education, analyses, and resources that accompany each CBR topic to ensure compliance in their organizations.
Resources:
www.cms.gov/files/document/2021-medicare-fee-service-supplemental-improper-payment-data.pdf-0
- Learn From Past Comparative Billing Reports - June 1, 2023
- 6 FAQs About CBRs - March 1, 2023
- How to Use Comparative Billing Reports as an Educational Tool - December 1, 2022
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