# The Documentation Gap
## Why CGM Claims Fail Before They're Filed
*Signal | STTIL Solutions | May 2026*

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### The Structural Problem

DMEPOS suppliers operate under a model no other healthcare provider uses.

A physician sees a patient and bills afterward. A pharmacy dispenses a prescription and collects at the counter. A DMEPOS supplier buys the equipment, delivers it to the patient, and then waits to find out if the claim gets paid.

The capital risk window on every CGM order is 30 to 90 days minimum. If the claim denies, the product is already gone. The supplier absorbs the cost.

That exposure would be manageable if denial rates were low. They are not.

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### The Denial Problem

CMS data for the most recent reporting period shows a 25.2% improper payment rate for CGM claims, representing $278.5 million in projected annual improper payments.

For a supplier managing 500 active CGM patients, that rate means roughly 126 denied claims per month on approximately $125,000 in monthly billing.

The appeal process does not make it right. After accounting for staff time at $50 to $118 per appeal attempt:

- 63% of denied claims are permanently written off
- The appeal process recovers less than 30 cents of every denied dollar after labor costs
- One in five CGM billing dollars is permanently lost

These are not fraud cases. CMS CERT data shows that nearly 1 in 3 glucose monitor claims have documentation errors, with over two-thirds of those errors driven by insufficient documentation. Not fraud. Not medical necessity disputes. Missing paperwork.

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### What Causes It

CGM coverage requires a documented chain of events that spans the patient, the prescribing physician, the DME MAC, and the supplier. A failure at any link in that chain becomes the supplier's liability.

The most frequent failure points:

**Prior authorization.** CGM codes sit on the CMS Master List, the staging ground for Required PA. Seven new HCPCS codes were added to the Required PA List on April 13, 2026, and the expansion pattern is consistent. Suppliers without clean PA submission habits now will be unprotected when CGM codes follow. A PA submitted but not yet affirmed, with a resupply due in five days, creates a decision most suppliers make the wrong way. If the PA subsequently denies, there is no recovery path.

**The 6-month visit requirement.** Continued CGM coverage requires a documented face-to-face or telehealth visit within 6 months of each resupply. That visit happens in the physician's schedule, not the supplier's. When it does not happen on time, the supplier finds out on the denial notice, not before.

**PECOS enrollment.** A prescriber whose PECOS enrollment lapses mid-cycle generates a hard denial with no appeal path. Most billing platforms check PECOS at intake, once. That is not enough.

**Payer and network changes.** UHC Medicare Advantage patients transitioning to Synapse Health network management, new codes added to required PA lists, and practice changes all create silent compliance gaps that standard workflows do not catch.

The common thread: the information is discoverable before the claim ships. The standard practice is to discover it after the denial.

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### Why 2026 Changes the Math

Several regulatory events have converged this year that raise the cost of a reactive approach:

**Prior authorization expansion, April 13, 2026.** Seven new HCPCS codes were added to the Required PA List. Suppliers not updated on the change are generating non-covered denials right now.

**PA affirmation exemption threshold, June 1, 2026.** Suppliers who achieve a 90% provisional affirmation rate may qualify for a PA exemption process. High-denial-rate operations will not qualify.

**Nationwide DMEPOS enrollment moratorium, February 27, 2026.** No new supplier enrollments are being processed. Existing suppliers have a protected market position and no recovery path if compliance failures accumulate.

**Competitive bidding for CGM, bidding window opens late Summer 2026.** Suppliers need to demonstrate clean claim rates and operational efficiency before CB bids are submitted. That window is now less than six months away.

**CGM monthly rental reclassification, effective January 1, 2028.** All CGMs move to a monthly rental model under DMEPOS competitive bidding. A supplier managing 500 patients today faces 6,000 individual billing cycles per year under the new model. Each one is a denial opportunity under a reactive workflow.

Every one of these events increases the cost of waiting.

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### What Proactive Looks Like

The operational shift is a sequencing problem, not a staffing one.

Today, most suppliers sequence like this: ship, bill, receive denial, appeal, write off. The documentation failure was present before the order was ever shipped. The supplier just did not know.

A proactive workflow sequences differently: review documentation status before shipment, identify gaps while there is still time to close them, ship when the claim will clear.

The staffing impact follows two curves. The reactive workflow drives a growing appeals backlog that compounds month over month. The proactive workflow drives a manageable, predictable outreach queue that does not grow with patient count. The crossover, where proactive staff time drops below reactive staff time, typically happens within the first three to five months.

**Signal** is a documentation readiness tracker built for this workflow. Suppliers import their order data; Signal produces a per-patient status report flagging documentation gaps for staff to act on before shipment. Signal identifies the gaps. Supplier staff closes them. The claim ships clean.

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### The Pilot

Signal is opening a limited pilot with three DMEPOS organizations. Priority is given to CGM-active suppliers who are currently managing documentation readiness in spreadsheets or billing platform workarounds and want a systematic approach before the 2026 deadlines arrive.

**[Request pilot access →](mailto:kisa@sttilsolutions.com)**

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*Signal is a product of STTIL Solutions LLC. Kisa, founder, brings 30 years across multiple managed care organizations to the DMEPOS documentation problem.*

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*Sources: CMS 2024 Medicare Fee-for-Service Supplemental Improper Payment Data; CMS CERT 2019 Glucose Monitor Review; VGM DMEPOS Appeals Guide; Experian State of Claims 2025; CMS Prior Authorization Expansion April 13 2026.*
