# Signal CGM — Final Composite Ranking and Leverage Analysis v3
### Asset Sale Primary · Pilot Secondary · MA + Medicaid Payer Scope
### STTIL Solutions LLC | April 2026

---

## Final Composite Ranking — Four Segments, MA + Medicaid Scope

| Rank | Segment | Asset (×0.50) | Pilot (×0.30) | SaaS (×0.20) | Composite |
|------|---------|--------------|--------------|-------------|-----------|
| **#1** | Billing company / DME RCM | 3.60 | 2.46 | 1.55 | **7.61** |
| **#2** | NikoHealth-type platform | 4.28 | 2.13 | 0.93 | **7.34** |
| **#3** | VGM Group / MSO | 3.58 | 1.08 | 1.06 | **5.72** |
| **#4** | Mid-size independent supplier | 1.65 | 2.09 | 1.62 | **5.36** |

**The 0.27-point gap between #1 and #2 is a sequencing signal, not a clear winner.**
Pilot with billing company → generate evidence → close NikoHealth asset sale at higher price.
These tracks are mutually reinforcing.

---

## Denial Cost Absorption vs. Recovery — Full Quantification

### Appeal Ladder Economics (Per ~$250 CGM Claim)

| Level | Timeline | Staff Cost | Overturn Rate | Net Yield |
|-------|----------|-----------|--------------|-----------|
| L1 Redetermination | 60–74 days | $25–$55 | 20–30% | $22.50 net after labor |
| L2 QIC Reconsideration | 60 days | $50–$118 | 50–65% | $58.50 net after labor |
| L3 ALJ Hearing | 6–18 months | $200–$1,500+ | 60–70% | ($687.50) net LOSS per claim |
| L4–5 Council / Court | Years | $5K–$50K+ | Variable | Not viable for CGM refills |

**MA-specific overlay:** MA L2 overturn rate is 63.9% (vs ~57% FFS) — but MA plans
deny more aggressively initially. Net: higher appeal labor per recovered dollar.

### Absorption Model — 500-Patient Supplier, One Month

```
500 active CGM patients | $125,000/month billing | 25.2% improper payment rate

126 denied claims (~$31,500 face value)
  ├── 38 not appealed → written off immediately        $9,500
  ├── 50 appealed at L1 only
  │    ├── 13 overturned (~27%)                        $3,250 recovered
  │    ├── 25 denied → abandoned                       $6,250 written off
  │    └── 12 escalated to L2
  └── 38 at L2 total (12 escalated + 26 direct)
       ├── 22 overturned (~57%)                        $5,500 recovered
       └── 16 denied → written off                     $4,000 written off

OUTCOME LEDGER:
  Permanently written off (all paths):   79 claims   $19,750   63%
  Recovered through appeals:             35 claims    $8,750   28%
  Still in process:                      12 claims    $3,000    9%

  Appeal labor cost (88 filings):                     $5,192/month
  Net recovery after labor:              $8,750 − $5,192 = $3,558
  Net loss including labor:             $19,750 + $5,192 = $24,942

ONE IN FIVE CGM BILLING DOLLARS IS PERMANENTLY LOST.
The appeal process recovers less than 30 cents of every denied dollar
after accounting for the staff labor required to run it.
```

---

## The Six Situations Where Suppliers Ship Despite Documentation Risk

### Situation 1: The PA-Pending Ship
**What:** PA submitted but not yet affirmed. Refill due in 5 days. Supplier
ships assuming approval will come through.
**Frequency:** Very high — 14–21 day MAC adjudication window routinely overlaps
refill schedule for reactive workflows.
**Outcome if PA denied:** Non-covered denial. Zero recovery path.
**Signal CGM intervention:** PA initiated 45 days out. Order blocked until
PA confirmed. Ship date never collides with adjudication window.

### Situation 2: The CMN Gray Zone
**What:** CMN expired 60 days ago. Doctor's office has been faxed three times.
Insulin-dependent patient is out of supplies. Supplier ships anyway.
**Frequency:** High. Physicians have 200 other patients. CMN renewal takes
60–90 days in slow practices.
**Outcome:** Denial. Backdated CMN rarely accepted at redetermination.
**Signal CGM intervention:** CMN expiration flagged 60 days out. Outreach
triggered at 45 days. Hold queue activates at 30 days if CMN not received.

### Situation 3: The New-Code Gap
**What:** CMS adds codes to Required PA list (7 new codes April 13, 2026).
Staff not notified. Existing workflow processes orders normally. No PA obtained.
**Frequency:** Episodic but acute at each list expansion. Hypothesis 2 in
validation-hypotheses.md tests whether this gap is live and unpatched now.
**Outcome:** Non-covered denial. No recovery.
**Signal CGM intervention:** Required PA code list maintained current and
applied automatically to all open refill windows.

### Situation 4: The PECOS Assumption
**What:** Prescriber was enrolled at intake 18 months ago. Practice changed.
PECOS lapsed. Supplier has no system to re-check at refill cycle.
**Frequency:** Moderate but growing. Practice instability post-COVID increasing.
**Outcome:** Hard denial. No appeal path if prescriber genuinely not enrolled.
**Signal CGM intervention:** NPPES checked at intake AND at each refill cycle.
Inactive NPI → order blocked → alert to supplier staff.

### Situation 5: The Synapse Blindside
**What:** Patient on UHC Medicare Advantage. Valid UHC PA in hand. Unknown to
supplier: UHC transitioned patient's state to Synapse Health (April 1, 2026).
Supplier not enrolled in Synapse. PA obtained through UHC portal not valid
in Synapse-managed network. Order ships. Denied: not in authorized network.
**Frequency:** Acute. 20+ states now in Synapse territory as of April 2026.
**Outcome:** Network access denial. Difficult appeal — supplier must prove
non-notification.
**Signal CGM intervention:** Payer-plan tracking layer flags UHC MA patients
in Synapse-covered states. Verifies Synapse enrollment before shipment.

### Situation 6: The Continuity Bridge
**What:** Coverage lapsed. Supplier working to restore. Patient calls: out of
sensors, insulin-dependent. Supplier provides bridge supplies with no active
PA, no valid CMN, no documentation.
**Frequency:** Low per patient; high consequence. The end state of situations
1–4 going unmanaged.
**Outcome:** Full product cost absorbed. No billing path.
**Signal CGM intervention:** Situations 1–4 never reach Situation 6 when
caught 45 days out. This situation is structurally prevented by the other five.

---

## Workflow Leverage Analysis

| Step | Financial Impact/Event | Frequency/Month | Preventability | Leverage Score |
|------|----------------------|----------------|----------------|----------------|
| **Prior Authorization** | $250 hard write-off; zero recovery path | HIGH: 15–25 at-risk refills in 500-pt book | HIGH: PA tracked 45 days out; ship blocked until confirmed | **9.2 / 10** |
| **Refill Tracking (Coverage Clock)** | Enables all other steps | HIGH: every active patient every month | HIGH: core calendar engine | **8.8 / 10** |
| **6-Month Visit Compliance** | $250/claim; 55% recoverable at L2 | MODERATE: 8–15 patients/month in mature book | HIGH: visit window calculated from refill date | **8.1 / 10** |
| **PECOS Validation** | $250 hard write-off; zero recovery | LOW: 2–5 events/month in 500-pt book | HIGH: NPPES checked at intake + each refill | **7.4 / 10** |
| **Intake Validation** | Prevents pipeline contamination | LOW: 5–15 new patients/month in mature book | HIGH: NPI, eligibility, base equipment, duplicates | **6.5 / 10** |
| **Audit Defense Log** | High if audit triggered ($50K–$500K) | LOW: episodic | MODERATE: time-stamped byproduct of all other steps | **5.8 / 10** |

### The Leverage Verdict

**Prior authorization is the single highest-leverage intervention point.** PA
failure = non-recoverable write-off. No appeal path. Zero exceptions. Every
other denial type has some theoretical recovery path. PA does not.

**Refill tracking is the enabling infrastructure, not a standalone lever.**
Without knowing when the next order ships, nothing else is actionable. It is
the architecture, not a feature.

**6-month visit compliance is the highest-frequency daily queue driver.** 8–15
patients per month, every month, in a 500-patient mature book. Prevented before
shipment is worth more than 57% chance of recovery after denial.

**Audit defense is the second story for asset sale conversations.** After daily
denial prevention, before competitive bidding urgency. In the current OIG
enforcement environment, "your customers can prove proactive compliance" is a
meaningful product differentiator.

---

## Asset Sale One-Liner

> "Signal CGM gives the buyer's customers 45 days to fix what would otherwise
> cost them 20% of their CGM revenue — and generates a compliance record that
> defends them against the government enforcement environment that's already active."

---

## Sources
- [CMS 2024 CGM Improper Payments — 25.2% rate](https://www.cms.gov/training-education/medicare-learning-networkr-mln/compliance/medicare-provider-compliance-tips/glucose-monitoring-supplies)
- [VGM DMEPOS Appeals Guide](https://www.vgm.com/communities/navigating-dmepos-appeals-processes-a-strategic-guide-for-providers/)
- [Denial Management Metrics](https://www.panahealthcaresolutions.com/blogs/denial-management-metrics-for-faster-reimbursement/)
- [Experian State of Claims 2025](https://www.experian.com/blogs/healthcare/state-of-claims-2025/)
- [KFF: MA Prior Authorization 2024](https://www.kff.org/medicare/nearly-50-million-prior-authorization-requests-were-sent-to-medicare-advantage-insurers-in-2024/)
- [OIG CGM Enforcement Priority 2025](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/)
- [UHC/Synapse Health Expansion — UHCprovider.com](https://www.uhcprovider.com/en/resource-library/news/2025/synapse-health-manage-dme-orders.html)
- [CGM Fraud Schemes — Qlarant](https://www.qlarant.com/knowledge/blog/continuous-glucose-monitor-fraud-schemes/)
- [Ossur Medicare Appeals Timeline Guide](https://www.ossur.com/en-us/professionals/ossur-rr/appealing-denied-medicare-claims-redetermination-reconsideration-and-alj)
