Legal
McDermott Compliance Clinic Examines Chronic Care Management Billing Risks
McDermott Will & Emery published a compliance analysis examining chronic care management (CCM) services billing, coding, audit exposure, and enforcement risk across Medicare and Medicaid programs. The analysis addresses how providers can structure CCM programs to minimize compliance risk during government audits and investigations. It covers documentation requirements, time-tracking protocols, and common billing errors that trigger OIG scrutiny. The guidance is relevant for Medicaid managed care plans and providers offering CCM services under capitated or fee-for-service arrangements.
Why it mattersCCM billing errors are a known OIG audit target, and Medicaid managed care plans contracting with providers offering these services face downstream liability for improper claims and quality deficiencies.