Downcoded

Who Reads the CERT Letter at Your Practice?

On Friday CMS deletes the option that let your MAC sit on an unanswered CERT records request, and requires feedback to close at least 30 days before your last chance to send the chart. Unanswered requests already cost Medicare $3.46 billion last year, the only documentation category that rose while the overall improper payment rate fell, and for urological supplies they are 69.4 of the 74.1 percent error rate.


Medicare paid for urological supplies last year and got 74.1 percent of it wrong.

Coding was not the problem. Medical necessity accounted for 0.0 percent of the error.

93.7 percent of it was a chart nobody sent.

That is CERT's 2025 finding, and on Friday CMS rewrites the manual sections that govern what happens after the letter goes unanswered.

"What happens to a claim between the day the request lands in the wrong bin and the day the money comes back?"

The instrument is Transmittal 13890, change request 14539, issued July 30 with an effective and implementation date of August 28. It revises five pieces of Chapter 12 of the Program Integrity Manual plus one exhibit. Section IV of the transmittal, Provider Education, reads "None." Impacted Contractors reads "None." CMS's own policy note says the CR "does not involve any legislative or regulatory policy."

It moves money anyway.

What Comes Off the Page on Friday

Five changes, in CMS's order:

  1. New language in 12.4.1.E on how CERT scores a claim that has multiple versions.
  2. Deletion of the option letting a MAC "collect an overpayment within 10 business days of the deadline for entering final feedback for error code 99 claims."
  3. A new floor: "regardless of which option the MAC selects," feedback must be complete "at least 30 days prior to the deadline for submitting late documentation."
  4. Deletion of "all language regarding potential fraud investigations as it no longer applies to the CERT process for improper payment review and reporting."
  5. A revised CERT Documentation Center address, fax number, and email address in the sample additional documentation request letter.

Numbers 1, 2 and 5 are the ones that reach your cash.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

$50 a month, or $500 a year.