Signal/CGM-Denial-Prevention/01-Claude-Outputs/Assets/signal-cgm-pitch-v2-professional.md

# Signal CGM — Asset Sale Overview
## Professional Edition
### Strategic Acquisition for DME-Focused Revenue Cycle Management Organizations

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> SIGNAL CGM
> A CGM-Specific Denial Prevention and Compliance Intelligence Platform
> for DME Revenue Cycle Management Organizations
>
> Asset Acquisition and Licensing Opportunity | April 2026
> STTIL Solutions LLC | kisasttil@gmail.com

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### The Problem Your Clients Cannot Solve Alone

CMS's 2024 Medicare Fee-for-Service data puts the CGM improper payment rate at
**25.2% — $278.5 million in projected annual overpayments** on glucose monitor
billing. Of that figure, 94.2% traces directly to documentation deficiencies:
missing or expired Certificates of Medical Necessity, prior authorizations not
obtained before shipment, undocumented 6-month physician visits, and prescriber
PECOS enrollment failures. Less than 6% reflects medical necessity disputes or
coverage policy conflicts.

The financial consequence for a supplier billing 500 active CGM patients monthly
runs deeper than the denial rate suggests. After accounting for appeal labor,
write-off timing, and the hard limits of the five-level Medicare appeals process,
**approximately 63% of denied CGM claim value is permanently absorbed** — not
recovered through redetermination or QIC reconsideration. The net effect on a
$125,000/month CGM billing book: a structural revenue loss of roughly $25,000
per month, or **20% of gross CGM billing**, that does not appear as a line item
in any supplier's P&L but is reflected across AR aging, appeal staffing overhead,
and uncompensated product cost.

This is the problem Signal CGM was built to eliminate — not by improving the
appeals process, but by making the appeals process unnecessary.

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### Six Workflow Leverage Points, in Priority Order

**1. Prior Authorization Tracking (Highest Leverage — No Recovery Path if Missed)**
PA not obtained before CGM shipment is the only denial type with zero appeal
recovery. Signal CGM initiates PA tracking 45 days before the projected refill
date — sufficient runway for the MAC's 14–21 day adjudication window plus a
resubmission buffer — and blocks order release until PA is confirmed in the
system. The April 13, 2026 expansion of the Required Prior Authorization list
and ongoing MA plan-specific requirements (UHC non-T1D since September 2024)
are automatically reflected in the current HCPCS code tracking layer.

**2. Refill Tracking / Coverage Clock (Enabling Architecture)**
A predictive refill calendar keyed to each patient's last dispense date, device
type, and payer-specific wear-day rules generates the operational foundation for
every other intervention point. Without forward visibility into the refill
schedule, PA initiation, CMN flagging, and visit compliance checks are reactive
lookups rather than automated workflow triggers.

**3. 6-Month Physician Visit Compliance (Highest Frequency Preventable Denial)**
Medicare's continued CGM coverage requirement mandates a documented in-person
or telehealth visit with the treating practitioner every six months. In a mature
500-patient book, 8–15 patients per month are approaching or past this window.
Unlike PA failures, missed-visit denials carry a 50–65% QIC overturn rate when
documentation can be obtained retroactively — but preventing the denial is worth
more than recovering half of it post-filing. Signal CGM surfaces each patient's
visit window as a prioritized outreach task 30+ days before the refill date.

**4. Prescriber PECOS Validation at Each Refill Cycle (Hard Write-Off Prevention)**
Medicare requires that the ordering physician maintain active enrollment at the
time each order is placed — not merely at the time of initial patient intake.
No incumbent DME billing platform currently re-validates prescriber enrollment
status at the refill cycle level. Signal CGM queries the NPPES registry against
the ordering provider's NPI at each scheduled refill and routes any inactive or
mismatched NPI to a supplier alert queue before the order can release.

**5. Intake Validation (Pipeline Defense)**
At new patient intake, Signal CGM performs eligibility verification, duplicate
claim history check, base equipment record validation (M124), and initial
prescriber PECOS status check before any first order is authorized.

**6. Audit Defense Log (Compliance Record as System Byproduct)**
Every pre-submission check generates a time-stamped audit log entry documenting
what was verified and when. In the current enforcement environment — with $1.9B
in DMEPOS improper payments under active OIG scrutiny, CGM explicitly identified
as a 2026 nationwide enforcement priority, and $1.8B in payments suspended by
CMS's Fraud Defense Operations Center in 2025 — a defensible compliance record
distinguishes a legitimate supplier from an audit target when the MAC issues an ADR.

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### The Pilot Offer: 60-Day Proof of Concept on Live Client Data

We are offering a structured 60-day pilot at no cost or obligation.

Select two to three CGM-active clients from your book. Signal CGM runs against
their live billing data — tracking open refills, flagging PA status gaps, CMN
expirations, and visit compliance windows across their active CGM patient roster.
At day 30 and day 60, we deliver a denial risk exposure report: claims that would
have shipped without documentation in hand, segmented by denial type and estimated
dollar exposure.

The pilot does not require replacing or integrating with existing billing software.
Signal CGM operates as a parallel layer over whatever clearinghouse or platform
the client currently uses. PHI handling during the pilot is governed by a Business
Associate Agreement executed before data access begins.

At the conclusion of 60 days, you hold a documented, client-specific before-and-after
comparison. That evidence either supports a deployment decision or it does not.
There is no obligation if the results do not meet your threshold.

---

### The Ask

**Option 1 — Full Asset Acquisition**
One-time acquisition: **$45,000–$65,000**

Includes: full Python/FastAPI source code, coverage calculator, audit logger,
PostgreSQL data models, payer rules configuration, complete research library
(market research, compliance roadmap, BAA framework), 30-day live knowledge
transfer with the STTIL Solutions founder, and the CLAUDE.md AI development
context enabling immediate continuation of development with Claude Code at
zero ramp-up cost. No licensing fees, no royalties, no ongoing STTIL involvement
unless contracted separately.

Buyer white-labels the product, deploys across their client base, and captures
the full downstream revenue.

**Option 2 — Per-Seat Licensing**
**$75 per supplier client per month** (volume negotiable above 25 seats)

Includes ongoing payer rule updates, Required PA code list maintenance, and
access to product improvements. A 20-client deployment at $75/month represents
$1,500/month in licensing cost against a conservative $9,000–$18,000/month in
recovered denial revenue across those clients — before accounting for staff
labor savings on appeal management.

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### Three Objections Addressed Directly

**"The cost isn't justified at our current scale."**
The financial threshold for ROI is low. A single client with 300 active CGM
patients billing $75,000/month, running at the documented 25% improper payment
rate, absorbs approximately $11,200/month in net CGM write-offs after exhausting
the appeal process. If Signal CGM prevents 40% of those — the conservative end
of what pre-submission PA and CMN tracking demonstrably delivers — that client
recovers $4,500/month. Against a $75/month per-seat cost, that is a 60-to-1
return on a single deployment. The 60-day pilot makes this calculation concrete
on your clients' actual numbers.

**"This tool reduces the complexity that makes our billing services valuable."**
Signal CGM operates exclusively in the pre-submission window — the 45 days before
a claim exists. It does not touch denial management, appeals coordination, payer
negotiation, remittance reconciliation, or any other function that defines your
current service relationship. What it does is give your clients fewer denials to
manage, which reduces the reactive workload on your team without displacing any
service functions you bill for. The more accurate framing: Signal CGM converts
reactive denial management — which your staff absorbs at $50–$118 per appeal
cycle — into a proactive workflow your clients pay you a premium to maintain.
It is a service tier expansion, not a service substitution.

**"We can't expose client PHI to a third-party system."**
Signal CGM was designed from the architecture level with this constraint as
non-negotiable. The system ingests five fields only: patient ID (the supplier's
internal account number, not a Medicare beneficiary identifier), device type,
shipment date, quantity, and payer code. No patient names, dates of birth, Social
Security numbers, diagnoses, or contact information enter the system at any point.
All audit logs hash even the patient ID before storage. The system is self-hosted
— it runs on your infrastructure or your client's infrastructure, not on STTIL's
servers. Data never transits a third-party network. The Business Associate
Agreement and full compliance documentation package are included in both
acquisition and licensing structures.

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**Next Step: Schedule the pilot conversation.**
kisasttil@gmail.com | STTIL Solutions LLC | Signal CGM

*This document is a confidential business communication intended for the named
recipient only.*

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### Sources
- [CMS 2024 CGM Improper Payment Rate — 25.2% / $278.5M](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/)
- [Federal Authorities Targeting CGM Claims — National Law Review](https://natlawreview.com/article/federal-authorities-are-targeting-continuous-glucose-monitoring-cgm-device)
- [MA Prior Authorization Denial Rates — KFF 2024](https://www.kff.org/medicare/nearly-50-million-prior-authorization-requests-were-sent-to-medicare-advantage-insurers-in-2024/)
- [UHC/Synapse Health DME Orders — UHCprovider.com](https://www.uhcprovider.com/en/resource-library/news/2025/synapse-health-manage-dme-orders.html)
- [CMS Prior Authorization Expansion April 13, 2026](https://www.hcintellect.com/post/medicare-dmepos-prior-authorization-expansion-effective-april-13-2026)
- [Denial Management Metrics](https://www.panahealthcaresolutions.com/blogs/denial-management-metrics-for-faster-reimbursement/)