On March 16, 2026, the OIG formally added a new active audit project to its Work Plan: a targeted review of Medicare Part B payments for Chronic Care Management services at risk of noncompliance with foundational program requirements. Project OAS-26-09-007 is currently in progress. Estimated completion is FY2028.
This is not a proposed rule or a future risk. It is an active federal audit, driven by substantial growth in CCM billing from 2019 through 2024. The OIG’s focus is straightforward: whether patients billed under CCM actually meet the chronic conditions criteria Medicare requires, and whether the documentation supports the services claimed.
What Auditors Are Looking For
Prior OIG reviews of CCM identified improper payment rates as high as 67.4% in targeted samples. The patterns that generated those findings are the same ones this audit will examine. Three areas carry the highest risk:
- Time ledger integrity. CCM requires a minimum of 20 minutes of non-face-to-face clinical staff time per calendar month, directed by a qualified provider. Auditors look for rounded entries, time credited to administrative rather than clinical staff, and time that overlaps with other billed services.
- Care plan documentation. A comprehensive, patient-specific electronic care plan is required. Generic templates that do not reflect the patient’s individual chronic conditions, current medications, and care coordination activity will not hold up. Documentation that the care plan was shared with the patient is also required.
- Patient eligibility and consent. Patients must carry two or more chronic conditions expected to last at least 12 months and place the patient at significant risk. Practices must document clinical justification for eligibility and proof of informed consent before services begin.
Enforcement Reality
False Claims Act enforcement in this space is active. A provider organization settled CCM-related FCA allegations for $14.9 million in a recent enforcement action. The exposure is not theoretical.
The Audit Is a Pressure Test, Not a Reason to Stop
The programs that will not survive this scrutiny are the ones where billing activity outpaced clinical documentation. The ones that will hold up are the ones where every claim is backed by a verified time ledger, an updated care plan, documented consent, and evidence of genuine care coordination.
That description is not a compliance checklist. It is what a well-run CCM program looks like in practice. The audit draws a clear line between CCM as a billing program and CCM as a care model. For practices that built it correctly, this is a validation of existing infrastructure.
What the Forthcoming Whitepaper Will Cover
Vivo Care will shortly publish a deep-dive whitepaper, featuring insights from our Medical Director, Dr. Aamir Iqbal, that addresses what compliant, clinically sound CCM infrastructure requires across four areas:
- Financial: The reimbursement structure of CCM in detail, including the logic behind the 99439 add-on code and what practices consistently leave on the table by not understanding how time-based billing works under the current Physician Fee Schedule.
- Compliance: What we call substantial exposure: the gap between what practices believe their documentation supports and what an auditor will actually accept. Pre-bill claim logic, time ledger standards, and the care plan evidence requirements that distinguish compliant programs from ones that will not survive scrutiny.
- Operations: What scalable CCM infrastructure looks like, including the difference between Self-Managed and Managed Clinical models and how each affects compliance posture and program sustainability.
- Clinical: What continuous engagement between visits actually produces. Earlier identification of complications before they escalate, reduced fragmentation across the care team, and documented physiologic improvement in patient populations that are actively monitored.
Next Steps
If your practice is billing CCM, now is the time to review your documentation infrastructure against the standards the OIG has already published. The forthcoming whitepaper will provide a detailed framework for doing that.
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* Disclaimer: The information provided in this announcement and the forthcoming whitepaper is for educational and informational purposes only and does not constitute legal, medical, or professional billing advice. Medicare billing guidelines, coding requirements, and regulatory interpretations are subject to frequent change. Healthcare organizations should always consult with qualified healthcare legal counsel and certified medical billing professionals to ensure their specific care management programs comply with all federal and state regulations prior to submitting claims.
Sources and Further Reading
- OIG Work Plan Project OAS-26-09-007: Audit of Medicare Payments for Chronic Care Management Services at Risk of Noncompliance. Announced March 16, 2026. Active.
- Centers for Medicare and Medicaid Services: CMS Physician Fee Schedule: Chronic Care Management Services.
- CMS Medicare Learning Network: Chronic Care Management Services MLN Booklet, updated 2024.
- Office of Inspector General: OIG Semiannual Report to Congress. U.S. Department of Health and Human Services.