# Signal CGM — Segment Scoring Model v1
### Explicit Criteria, Weights, and Rankings Across Three Objectives
### STTIL Solutions LLC | April 2026

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## Scoring Architecture

Three independent rankings. Each uses different criteria, weights, and success
definitions. A segment that ranks #1 for SaaS ICP may be wrong for a pilot and
irrelevant for an asset sale. Treat them as separate decisions.

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## Model 1: Best SaaS ICP for MRR/ARR

| Criterion | Weight | What it measures |
|-----------|--------|-----------------|
| Pain intensity | 25% | How acutely the segment feels the CGM denial problem |
| Willingness / ability to pay | 20% | Named budget, ROI clarity, buyer who can sign |
| Revenue per customer (ARR × LTV) | 20% | Monthly contract × expected contract duration |
| Sales cycle speed | 15% | Weeks from first contact to signed contract |
| Churn durability | 10% | Still exists and values the tool in 24 months? |
| Reachability at scale | 10% | Find and reach efficiently without large sales org |

### SaaS ICP Scores

| Segment | Pain (25%) | Pay (20%) | ARR×LTV (20%) | Cycle (15%) | Churn (10%) | Reach (10%) | Score |
|---------|-----------|-----------|--------------|-------------|------------|-------------|-------|
| Mid-size supplier (10–50 emp) | 9 | 8 | 8 | 7 | 6 | 7 | **7.80** |
| Billing company / DME RCM | 8 | 7 | 7 | 5 | 8 | 6 | **6.95** |
| Small supplier (2–8 emp) | 10 | 5 | 4 | 6 | 4 | 8 | **6.40** |
| VGM Group / MSO | 5 | 4 | 7 | 3 | 9 | 5 | **5.30** |
| DME platform vendor (NikoHealth) | 3 | 4 | 8 | 2 | 9 | 3 | **4.65** |
| State / national association | 2 | 1 | 1 | 3 | 7 | 9 | **2.55** |
| Grant-funded / QI org | 3 | 2 | 2 | 2 | 4 | 4 | **2.60** |

**Key rationale:**
- Mid-size supplier leads because they have pain + budget + ROI clarity at $199–$399/month
- Small supplier has maximum pain (10/10) but minimum reliability — high churn risk as CB 2028 approaches
- Billing company scores #2: absorbs denial labor directly; LTV longer than any individual supplier
- NikoHealth scores low on SaaS — they are an asset buyer, not a subscriber

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## Model 2: Best Buyer for Asset Sale / Strategic Handoff

| Criterion | Weight | What it measures |
|-----------|--------|-----------------|
| Distribution reach | 30% | How many suppliers does this buyer already reach? |
| Strategic need | 25% | Documented feature gap; would they build it otherwise? |
| Price ceiling | 20% | How much would a motivated buyer plausibly pay? |
| Speed to close | 15% | Weeks from conversation to signed term sheet |
| Build vs. buy calculus | 10% | Is acquiring faster than building given CB 2028 window? |

### Asset Sale Scores

| Segment | Distribution (30%) | Need (25%) | Price (20%) | Speed (15%) | B/B (10%) | Score |
|---------|-------------------|-----------|------------|-------------|-----------|-------|
| DME platform vendor (NikoHealth) | 10 | 9 | 9 | 3 | 7 | **8.20** |
| VGM Group / MSO | 10 | 7 | 7 | 4 | 8 | **7.55** |
| Billing company / DME RCM | 7 | 8 | 6 | 5 | 7 | **6.75** |
| State / national association | 8 | 4 | 2 | 2 | 3 | **4.40** |
| Mid-size supplier | 1 | 5 | 2 | 4 | 3 | **2.85** |
| Small supplier | 1 | 4 | 1 | 3 | 2 | **2.10** |
| Grant-funded / QI org | 3 | 3 | 2 | 1 | 2 | **2.40** |

**NikoHealth (#1 asset buyer) rationale:**
- Already serves the exact buyer profile; CGM feature gap is documented and real
- API-first architecture makes integration technically trivial
- CB 2028 window makes buying faster than 6–9 month internal build
- Price ceiling is 3–5× current $25K–$60K ask for a motivated platform buyer

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## Model 3: Best Pilot Validation Partner

| Criterion | Weight | What it measures |
|-----------|--------|-----------------|
| Data accessibility | 25% | Structured CGM billing data with denial reason codes |
| Cooperation likelihood | 20% | Will they actively participate and give feedback? |
| Signal quality | 20% | Will pilot results generalize to target market? |
| PHI / compliance overhead | 20% | BAA and data security burden |
| Feedback loop speed | 15% | How quickly is denial rate change measurable? |

### Pilot Scores

| Segment | Data (25%) | Coop (20%) | Signal (20%) | PHI (20%) | Speed (15%) | Score |
|---------|-----------|-----------|-------------|----------|------------|-------|
| Billing company / DME RCM | 10 | 7 | 10 | 6 | 6 | **8.00** |
| Mid-size supplier | 8 | 8 | 9 | 5 | 8 | **7.60** |
| DME platform vendor | 10 | 4 | 10 | 7 | 4 | **7.30** |
| Small supplier | 6 | 9 | 7 | 5 | 7 | **6.75** |
| VGM / MSO | 3 | 5 | 4 | 4 | 3 | **3.80** |

**Billing company leads pilot scoring** because they have multi-supplier,
multi-plan, multi-jurisdiction billing data — the fastest path to H1 validation
(denials are documentation-fixable) across a meaningful sample size.

---

## Government Enforcement Context

| Finding | Source | Strategic Implication |
|---------|--------|----------------------|
| CGM improper payment rate: 25.2% / $278.5M/yr | CMS 2024 | One in four CGM dollars improperly paid |
| 94.2% from documentation failures | CMS 2024 | Not fraud — fixable workflow gaps |
| $1.9B total DMEPOS improper payments FY2024 | OIG | CGM is highest-scrutiny category |
| $1.8B in payments suspended 2025 | CMS Fraud Defense Ops | Enforcement is executing at scale now |
| CGM as explicit 2026 enforcement priority | OIG / DOJ | Legitimate suppliers get caught in sweeps |
| Unequal enforcement: pharmacy vs DMEPOS | CMS-2025-0242-0025 | DMEPOS held to higher standard than pharmacy for same product |

**The dual-edge positioning:** Signal CGM's audit log is not just a billing tool —
it is liability documentation. A supplier who can show time-stamped pre-submission
checks has a defensibility argument when the MAC issues an ADR.

---

## NikoHealth Foothold Assessment

**Verdict: Credible and growing challenger. Not the market standard.**

| Indicator | Assessment |
|-----------|-----------|
| Architecture | Cloud-native, API-first — genuine advantage over Brightree |
| Pricing | More accessible for small suppliers than Brightree ($600–$1,500+/mo) |
| Market position | Capturing switchers from legacy platforms; not dominant |
| Customer count | G2 review volume suggests low hundreds, not thousands |
| CGM-specific intelligence | Generic authorization alerts; no 6-month visit tracking, no MAC-jurisdiction rules, no 45-day runway logic |
| Competitive risk | Could close the CGM gap in 6–9 months of focused engineering |

**Asset sale timing window: open but not permanent.** NikoHealth's API-first
architecture makes acquisition or licensing integration technically trivial
relative to Brightree's legacy stack.

---

## Sources
- [CMS 2024 CGM Improper Payment Data](https://www.cms.gov/training-education/medicare-learning-networkr-mln/compliance/medicare-provider-compliance-tips/glucose-monitoring-supplies)
- [OIG 2025: CGM Payments Exceeded Supplier Costs](https://oig.hhs.gov/reports/all/2025/medicare-payments-for-continuous-glucose-monitors-and-supplies-exceeded-supplier-costs-and-retail-market-prices-indicating-medicare-can-save-at-least-tens-of-millions-of-dollars-in-one-year/)
- [KFF: MA Prior Authorization 2024](https://www.kff.org/medicare/nearly-50-million-prior-authorization-requests-were-sent-to-medicare-advantage-insurers-in-2024/)
- [Unequal DME/Pharmacy Enforcement — CMS Comment Record](https://downloads.regulations.gov/CMS-2025-0242-0025/attachment_1.pdf)
- [NikoHealth G2 Reviews 2026](https://www.g2.com/products/nikohealth/reviews)
- [DME/HME Software 2026 — Coruzant](https://coruzant.com/software/dme-and-hme-software-in-2026/)
- [DOJ $14.6B Healthcare Fraud Takedown 2025](https://www.justice.gov/opa/pr/national-health-care-fraud-takedown-results-324-defendants-charged-connection-over-146-billion)
- [Federal Authorities Targeting CGM Reimbursement — Nat'l Law Review](https://natlawreview.com/article/federal-authorities-are-targeting-continuous-glucose-monitoring-cgm-device)
