Downcoded
August 16, 20264 min readFree

Where Did the RAC Pipeline Go?

CMS runs two Recovery Audit topic lists: one for what the auditors are cleared to review, one for what they have proposed reviewing next. The proposed list returns "No data available", and the approved list has picked up eight new topic numbers since January 2024 while re-dating sixteen old ones.

CMS publishes two lists that between them describe everything a Recovery Audit Contractor is allowed to look at. The approved list is the working inventory, the one your denials will cite.

The proposed list is the early warning: topics CMS is weighing, posted so the field can comment before anyone's records get pulled.

Open the proposed list this morning and the page answers with three words.

No data available.

Nothing is queued. And the approved list, read the same morning, holds 163 topics, which is a smaller number than most compliance calendars assume.

What the Approved List Actually Holds

The 163 entries carry topic numbers running 0001 through 0229, so 66 of the numbers in that sequence are simply gone from the published list. Numbers get issued in order and some of them get pulled.

Review type splits 91 complex against 71 automated, with one row, 0162 Computerized Tomography Coronary Angiography, whose Review Type cell on the CMS page is empty (Cotiviti's own regional file calls it complex). The distinction is the whole workload question: automated review runs at the system level and arrives as an informational letter, complex review requires a human to read the chart and therefore starts with an ADR.

Now the part that does not match the list's reputation. Approval dates run from 2017-02-01 to 2026-07-15, and 106 of the 163 topics, 65%, carry a date from 2017, 2018 or 2019 (chart below). Plot topic number against date and the intake curve is obvious: heavy through 2019, thinning hard after 2021, nearly flat since.

The Dates Move

Look at the orange column sitting under the diagonal at August 2025. Those are old topic numbers carrying a brand-new date.

The Internet Archive's capture of the same CMS page from April 3, 2025 settles what that means. Topic 0116, Modifiers TC and PC: Incorrect Coding, read 2018-10-09 then.

It reads 2025-08-27 now. Same number, same issue name, new date. (One topic in that capture, 0086, is not on today's list at all.)

So the Date Approved column gets overwritten in place, and the list publishes no revision history. Which changes the arithmetic on what looks like recent growth:

  • Since January 2024, eight new topic numbers have appeared: 0222, 0223, 0224, 0225, 0226, 0227, 0228, 0229.
  • Over the same period, sixteen topics numbered 0221 or lower picked up a 2024-or-later date. Fourteen of those sixteen landed across three consecutive days, August 26, 27 and 28, 2025.

Five of those fourteen are DME: positive airway pressure devices, ventilators, home oxygen, immunosuppressive drugs, and DME rentals billed twice in a month.

The rest run through annual wellness visits, vitamin D assay testing, CT coronary angiography, spinal cord neurostimulation, ESRD monthly capitation, and destruction of premalignant lesions.

Worth putting the calendar next to it without drawing a line between the two. CMS's own program page records that on April 28, 2025 it awarded Cotiviti GOV Services LLC the Region 3, 4 and 5 contracts, taking Region 5 (nationwide DMEPOS, home health and hospice) away from Performant, and that CMS "anticipates Cotiviti GOV Services LLC will begin reviews in the Summer (2025)." Four months later, fourteen topics got re-dated in three days, five of them DME.

The Four That Are Genuinely New

Everything approved in 2026 fits in a short list, and three of the four are complex, which means records:

  1. 0226, External Counterpulsation Therapy for Severe Angina. Complex, professional services, HCPCS G0166, dated 2026-03-15.
  2. 0227, Wireless Capsule Endoscopy. Complex, outpatient hospital and professional services, CPT 91110 and 91111, dated 2026-03-15.
  3. 0228, Therapy Claims Billed with KX Modifier. Complex, outpatient hospital and professional services, dated 2026-04-15. The code list runs across PT, OT and speech, and the review is aimed straight at the attestation: the KX modifier says the clinician has documented why therapy above the threshold is still reasonable and necessary, and this topic asks the chart to prove it.
  4. 0229, Anesthesia During Spine Pain Management Procedures. Automated, dated 2026-07-15. CPT 01992 denies when it lands on the same date of service for the same beneficiary as facet joint injections, facet joint denervation, or epidural steroid injections. This one carries a bounded window: dates of service before 06/05/2023 and on or after 12/02/2024 are excluded.

0228 is the broad one. If you run outpatient therapy, that single topic reaches more of your claim volume than the other three combined.

Final Thoughts

The topics themselves print the lookback: exclude claims whose paid claim date is more than three years before the ADR letter. A request landing in your mail room this week reaches into 2023 volume you have already closed the books on.

None of that is new. What is new is how small and how knowable the surface has become.

There is no pipeline to watch, nothing pending comment, and one spreadsheet with 163 rows that describes the entire universe of what a RAC can open on you between now and whenever CMS starts issuing numbers again. It is worth an afternoon.

Thanks for reading.