Comparative Billing Reports

As part of the Centers for Medicare and Medicaid’s (CMS) continued focus on billing compliance, CMS has begun issuing Comparative Billing Reports (CBRs) to providers whose billing patterns are statistical outliers in comparison to their peers.

Although some Medicare Administrative Contractors (MACs) had been generating their own CBRs, CMS recently initiated a nationwide data mining initiative focusing on Medicare Part B billing data. The initiative compares billing data from an individual provider to state and national peer groups with formal reports being issued to providers who are deemed to be outliers in comparison to their peers.

CBRs are meant to be educational and assist providers in evaluating their compliance with Medicare’s coding and billing guidelines. Receiving a CBR doesn’t necessarily indicate that there is a problem. However, CMS does expect that providers who receive a CBR will perform a self-review of their coding and billing practices in order to determine why they are an outlier and correct any issues of non-compliance identified during the self-review.

In 2020, CMS has reviewed billing data and issued CBRs on shoulder arthroscopy. In 2019, some of the reviews and CBRs issued by CMS focused on;
– Mohs microsurgery
– Modifier 25 in dermatology
– Emergency Department services
– Office Visits, new and established
– Subsequent hospital care

For more information on CMS’s CBR initiative, please visit:

If you receive a CBR and would like assistance reviewing your billing data for compliance with Medicare guidelines, please contact the Office of Healthcare Compliance at or extension 4746.

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