Comparative Billing Report (CBR): What Medical Coders and Billers Need to Know
A Comparative Billing Report (CBR) is an educational tool used by Medicare to help providers, medical coders, and billing professionals understand how their billing patterns compare to national, state, and peer group data. These reports are designed to promote accurate coding, reduce improper payments, and help healthcare providers identify potential billing risks before they turn into audits.
CBRs are not audits. They are meant to be informational and proactive, giving practices a chance to review and improve their billing behaviors voluntarily.
Who Receives Comparative Billing Reports?
CBRs are sent to:
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Physicians and non-physician practitioners
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Medical clinics and group practices
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Hospitals and outpatient facilities
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Durable Medical Equipment (DME) suppliers
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Laboratories and specialty providers
Reports are issued when a provider’s billing data shows unusual patterns compared to others in the same specialty or geographic area.
What Information Is Included in a CBR?
A Comparative Billing Report typically includes:
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Commonly reported CPT® and HCPCS codes
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Frequency of services billed
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National, state, and peer comparison data
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Graphs showing where the provider falls in relation to peers
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Educational resources and documentation recommendations
Many CBRs focus on high-risk services such as E/M services, DME supplies, lab testing, and high-utilization procedures.
Why CBRs Matter in Medical Coding
CBRs help coders and billers:
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Spot overuse or underuse of certain CPT®/HCPCS codes
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Identify documentation gaps
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Confirm that coding aligns with national guidelines
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Reduce the chance of Medicare audits or recoupments
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Strengthen internal compliance programs
Consistent outlier billing patterns, if left uncorrected, can increase the risk of a Targeted Probe and Educate (TPE) review or more serious audits.
How Medical Coders Should Respond to a CBR
When a CBR is received, medical coding and billing teams should:
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Review frequently reported codes in the report
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Compare medical record documentation with billed services
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Confirm correct levels of E/M services
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Ensure modifiers are used correctly
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Check medical necessity and diagnosis-to-procedure linkage
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Perform internal audits on similar claims
This proactive approach helps prevent future payment denials and compliance issues.
Common Services Flagged in CBRs
CBRs often focus on:
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High-level E/M services
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Modifier -25 usage
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DME items and supplies
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Laboratory panels
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Physical therapy and rehabilitation services
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Injection and infusion services
These areas are targeted due to historically high improper payment risks.
How CBRs Help Prevent Audits
Although they are not audits, CBRs function as an early warning system. Providers who review and correct their billing after receiving a CBR can greatly reduce the chance of:
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Medicare overpayment demands
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Recovery Audit Contractor (RAC) reviews
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Zone Program Integrity Contractor (ZPIC/UPIC) investigations
Key Takeaways for Medical Coders
Comparative Billing Reports are valuable tools that help coders:
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Improve coding accuracy
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Strengthen documentation practices
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Support compliant reimbursement
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Protect providers from future audits
Rather than fear a CBR, coders should view it as a chance to reinforce best practices and elevate compliance standards.
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