On March 16, 2026, the HHS Office of Inspector General posted a new Work Plan item, project number OAS 26 09 007, status active. The objective sentence is short: review Medicare Part B payments for Chronic Care Management services that may be at risk of noncompliance with the requirement for multiple chronic conditions. No press release. No trade publication headline. Just a line item that will run audits through fiscal year 2028, aimed directly at whether the patients your practice is billing CCM for actually meet the eligibility standard on paper.
That standard is a three part test, and every part has to survive a chart review. The patient needs two or more chronic conditions. Those conditions have to be expected to last twelve months or until death. And they have to place the patient at significant risk of death, acute exacerbation, decompensation, or functional decline. CMS has paid for CCM since January 2015. Part B payments for the service increased substantially from calendar year 2019 through 2024, and OIG is now treating that growth curve the same way it treated the growth curve in remote patient monitoring and Applied Behavior Analysis this year: as a signal to go look at the documentation behind the billing, not just the billing itself.
This is not a hypothetical exposure. In June 2024, Bluestone Physician Services agreed to pay 14.9 million dollars to resolve allegations that it submitted E&M and CCM claims, including code 99490, that did not support the level of service billed, covering claims from 2015 through 2019. The government’s theory was not that Bluestone billed for care that never happened. It was that the documentation on file did not establish the multiple chronic conditions, duration, and risk criteria the code requires. That is the exact same documentation gap OIG’s new Work Plan item is now built to find at scale, across a Medicare population that has only gotten larger since Bluestone signed its Corporate Integrity Agreement.
This lands squarely on internal medicine, geriatrics, and family medicine, three of the specialties already named in our primary care cluster for HCC undercoding and administrative friction that erodes 12 to 15 percent of potential revenue before it is ever billed. CCM billing and HCC coding accuracy are not separate problems. Both depend on the same underlying discipline: chart documentation that names each chronic condition, ties it to a duration and a clinical risk, and does so in language a reviewer outside your practice can verify without calling you to ask. A practice that has been coding CCM off a diagnosis list instead of a documented risk narrative is not failing a technicality. It is building the exact fact pattern OIG just funded three years of audit work to find.
WeBill Health does not wait for a Work Plan item to become an audit letter before your CCM documentation is ready for one. Compliance is not a safeguard we bolt on. It is the standard every claim is held to, which means every CCM claim we touch is coded and documented so the multiple conditions, duration, and clinical risk criteria are provable in the chart on day one, not reconstructed after OIG asks for a sample. Our providers operate on a 98% clean claim rate, a 48 hour submission guarantee, and a 40% average A/R reduction, because audit ready documentation is built into the workflow before the claim exists, not assembled after a reviewer opens the file.
You do not need OIG to select your practice for its sample to find out whether your CCM documentation would survive the review. You need the number today.
Two ways to find out:
Get a Revenue Defense Audit. We run a forensic review of your existing A/R and surface the CCM documentation gaps, HCC undercoding exposure, and multiple conditions criteria this Work Plan item is built to catch.
Get your Revenue Defense Score. See exactly how exposed your practice is to denials, undercoding, and credentialing gaps, specialty by specialty.
Sources:
Audit of Medicare Payments for Chronic Care Management Services at Risk of Noncompliance, Project OAS 26 09 007, HHS Office of Inspector General, announced March 16, 2026: https://oig.hhs.gov/reports/work-plan/browse-work-plan-projects/audit-of-medicare-payments-for-chronic-care-management-services-at-risk-of-noncompliance
Chronic Disease Management Provider to Pay $14.9M to Resolve Alleged False Claims, U.S. Department of Justice, June 5, 2024: https://www.justice.gov/archives/opa/pr/chronic-disease-management-provider-pay-149m-resolve-alleged-false-claims
What the March 2026 OIG Work Plan Updates Reveal About Emerging Compliance Risk, Healthicity, April 7, 2026: https://www.healthicity.com/blog/what-the-march-2026-oig-work-plan-updates-reveal-about-emerging-compliance-risk
OIG Work Plan Targets Chronic Care Management: What Care Management Companies and Investors Need to Know, Nixon Law Group, March 31, 2026: https://www.nixonlawgroup.com/resources/oig-work-plan-targets-chronic-care-management-what-care-management-companies-and-investors-need-to-know
