US · guidance
CMS Pub. 100-08, ch. 7, § 7.2.2.13
Postpay Service Specific Medical Record Review
Medical record review requires a licensed medical professional to use clinical review
judgment to evaluate medical records. Service specific postpay medical record review of
claims requires that a benefit category review, statutory exclusion review, and/or
reasonable and necessary review be made after claim payment directed at a certain
service. This includes requests for, collection and evaluation of medical records or any
other documentation. The review is as a result of vulnerabilities determined by data
analysis and identified in the Medical Review strategy. If the requested documentation is
not received, it is not considered a medical record review. The failure of the provider to
submit documentation shall result in a denial. Contractors shall use Group Code: CO -
Contractual Obligation and Claim Adjustment Reason Code (CARC) 50 - these are non-covered services because this is not deemed a “medical necessity” by the payer and
Remittance Advice Remark Code (RARC) M127 - Missing patient medical record for
this service. For the purpose of calculating and reporting MR workload, cost and
savings, this is postpay medical record review and is not to be counted as a probe review.
7.2.2.14 - Data Analysis
(Rev. 444, Issued: 12-14-12, Effective: 04- 01- 13 (FISS and MCS); 07-01-13 (VMS);
Implementation: April 1, 2013 (Implementation of FISS and MCS); July 1, 2013
(Implementation of VMS)
Used to identify and verify potential errors to produce the greatest protection for the
Medicare program. Data analysis is an essential first step in determining whether
patterns of claims submission and payment indicate potential problems. It includes
simple identification of aberrancies in billing patterns within a homogeneous group, or
much more sophisticated detection of patterns within claims or groups of claims that
might suggest improper billing or payment. Data analysis is undertaken as a part of
general surveillance and review of submitted claims, conducted in response to
information about specific problems stemming from complaints, provider or beneficiary
input, fraud alerts, reports from CMS, other ACs, MACs, or independent government and
nongovernmental agencies.
Background The Contractor uses CERT findings, internal and external data sources,
review of claims, and information from other operational areas to
identify patterns of erroneous billing submissions and areas of over
utilization to target provider-specific review.
History
(Rev. 721; Issued: 06-09-17; Effective: 07-11-17; Implementation: 07-11-17)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
b9fc7cfc23d577fe06f38c5b05f028f287e473f2843fab0cbc8b50999801896b
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