2022 Compliance Trends

Identifying compliance trends and proactively evaluating them within your organization is a key component of an effective program.  As consultants, the experts at HBE are in the unique position to see national trends in non-compliance first hand.  We have taken the findings of our most recent engagements and combined them with government enforcement activities to identify our top 5 of what is hot in compliance right now:  

  1. Risk adjustment (HCC) coding
  2. Split/shared services
  3. Use of modifier 25
  4. Chronic care management (CCM)
  5. Preventive medicine/annual wellness visits (AWV)


In almost every case the root cause of errors is inadequate documentation, insufficient coder education and lack of oversight.  Here are just a few of the common errors we see:

  1. HCC codes assigned when the documentation does not support the condition was addressed or managed during the encounter.
  2. Split/shared services reported without the FS modifier and/or billed using a physician’s NPI when the documentation does not support the physician rendered the substantive portion of the encounter. Remember the rules are new for 2022!
  3. Assignment of modifier 25 when the documentation does not support any E/M services was performed in addition to a procedure or wellness service and/or the documentation does not support a significant and separately identifiable E/M.
  4. Reporting CCM services when the documentation does not support customized, measurable treatment goals and/or coordination of outside services and/or review and revision of plans of care.
  5. Reporting preventive medicine/AWV when the documentation does not support age appropriate counseling and anticipatory guidance and risk factor evaluation/reduction and/or does not contain written screening schedules and/or advance care planning discussions.


We offer a variety of consulting and compliance  partner services including:

  • Risk assessments
  • Internal investigations
  • CPT, HCPCS and ICD-10 accuracy reviews
  • Documentation improvement reviews
  • Development of corrective action plans
  • Development of policies and procedures
  • Development of customized education and training

We have expertise with multiple electronic health record and billing platforms that allow us to provide prompt assistance and ongoing support.

Let us help you achieve effective compliance in 2022!

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