October 2025 Newsletter

We’ve assembled the latest news for healthcare revenue cycle leaders to help you stay on top of industry challenges and adapt your revenue cycle management services to the challenges of USA medical billing.

Home Health Industry Threatened by Shutdown

The recent government shutdown is causing problems for the home health industry and home health care billing, pushing it over a telehealth cliff, limiting its patient pool, and adding administrative burden, according to Home Healthcare News. It’s also frozen the Acute Hospital Care at Home (AHCAH) program [1].

Risk Adjustment Audit Overhaul Struck Down

A federal judge in Texas has ruled that DHS violated the Administrative Procedure Act, failing to appropriately notify industry stakeholders and the general public about the changes in the medical coding audit rule. The suit was brought by Humana, challenging the September 2023 RADV overhaul. The ruling is being counted as a significant win for payers [2].

CMS Expects Medicare Advantage and Medicare Prescriptions Drug Programs to Remain Stable

The agency has announced that the average plan choices, premiums, and benefits for the MA program and Part D prescription drug program will be stable in 2026. Average premiums are expected to decline in both programs. CMS is releasing this information ahead of Medicare Open Enrollment [3].

Lab Developed Test Final Rule Rescinded

The FDA rescinded the final rule on laboratory developed tests. This action puts a formal end to a long-term effort to increase oversight in the industry. The agency has issued a new final rule, changing the definition of in vitro diagnostics to align with pre-2024 regulations [4]. Healthcare providers and medical billing companies should keep an eye out for changes that impact them. 

HCPCS Quarterly File Updated

The previously released HCPCS quarterly update for October has been updated as of 9/23/2025. The medical billing updates can be reviewed and downloaded by the public on the CMS website under the file name: October 2025 Alpha-Numeric HCPCS File (ZIP) [5].

E/M Billing and Coding Updates Released by CMS

CMS has published a revised MLN booklet, covering E/M services. This update concerns billing and medical coding updates for home or residence services, telehealth services, hospital outpatient clinic visits, critical care services, and more [6].

The Impact of Federal Funding Cuts on Health Systems

Becker’s Hospital Review has published an overview of the impact of the One Big Beautiful Bill Act to multiple areas of healthcare including Medicaid reductions, ACA subsidies, Medicare Advantage, 340B drug pricing programs, and NIH funding [7].

New ICD-10-CM Codes Announced

CMS has announced new ICD-10-CM codes that are effective October 1, 2025 for revenue cycle management services. These codes will impact discharges from October 1, 2025 to September 30, 2026. They will also impact patient encounters between October 1, 2025 and September 30, 2026 [8].

Humana to Pay $32M in Fees in False Claims Settlement

Humana has been ordered by a federal court to pay over $32 million in fees, including attorney’s fees, costs, and interest connected with the resolution of a False Claims Act case from 2024. The lawsuit was filed in 2016 by a former actuary for Humana who claimed that the company sent CMS fraudulent bids for the Walmart Part D prescription drug plan [9].

The AHA Pursues Commitments on Prior Auth Reforms

The American Hospital Association has encouraged HHS leadership to keep the promises they’ve made on prior authorization reforms for the hospital revenue cycle. The association sent a letter to CMS and HHS leaders, emphasizing the fact that 95% of hospitals report that staff time spent on prior auth approval has increased in the last year, increasing patient frustration and burden on providers [10].

New Epic Interoperability Features

Epic has launched multiple new data-sharing features at a recent interoperability conference. They include more prior authorization APIs, MyChart changes, and updates to align with federal interoperability standards [11].

 

References

[1] M. Gonzales, “Government Shutdown Halts Telehealth Flexibilities, Hospital-at-Home Waiver, Threatening Home Health Industry,” Home Health Care News, 1 October 2025. Available: https://homehealthcarenews.com/2025/10/government-shutdown-halts-telehealth-flexibilities-hospital-at-home-waiver-threatening-home-health-industry/.
[2] P. Minemyer, “Federal judge strikes down 2023 risk adjustment audit overhaul in win for Medicare Advantage plans,” Fierce Healthcare, 26 September 2025. Available: https://www.fiercehealthcare.com/payers/federal-judge-strikes-down-2023-radv-audit-overhaul-win-medicare-advantage-plans.
[3] CMS, “Medicare Advantage and Medicare Prescription Drug Programs Expected to Remain Stable in 2026,” 26 September 2025. Available: https://www.cms.gov/newsroom/press-releases/medicare-advantage-medicare-prescription-drug-programs-expected-remain-stable-2026.
[4] S. Kelly, “FDA rescinds LDT final rule,” TechTarget, Inc., 19 September 2025. Available: https://www.medtechdive.com/news/FDA-rescinds-LDT-final-rule/760645/.
[5] CMS, “HCPCS Quarterly Update,” 23 September 2025. Available: https://www.cms.gov/medicare/coding-billing/healthcare-common-procedure-system/quarterly-update.
[6] CMS, “Evaluation and Management Services,” September 2025. Available: https://www.cms.gov/files/document/mln006764-evaluation-management-services.pdf.
[7] E. Cerutti, M. Ashley, J. Emerson and E. Casolo, “What ‘federal funding cuts’ really mean for health systems,” Beckers Hospital Review, 29 September 2025. Available: https://www.beckershospitalreview.com/finance/what-federal-funding-cuts-really-mean-for-health-systems/.
[8] CMS, “ICD-10 Codes,” 1 October 2025. Available: https://www.cms.gov/medicare/coding-billing/icd-10-codes.
[9] J. Emerson, “Court orders Humana to pay $32M in fees following False Claims settlement,” Beckers Payer, 30 September 2025. Available: https://www.beckerspayer.com/legal/court-orders-humana-to-pay-32m-in-fees-following-false-claims-case/.
[10] American Hospital Association, “AHA Supports Administration Facilitating Health Insurer Pledge to Reform Prior Authorization,” 29 September 2025. Available: https://www.aha.org/lettercomment/2025-09-29-aha-supports-administration-facilitating-health-insurer-pledge-reform-prior-authorization.
[11] G. Bruce, “Epic unveils new interoperability features: 7 things to know,” Beckers Hospital Review, 25 September 2025. Available: https://www.beckershospitalreview.com/healthcare-information-technology/ehrs/epic-unveils-new-interoperability-features-7-things-to-know/.

The ABCs of Laboratory Billing- How Pathology Groups Can Stop Losing Revenue

The ABCs of Laboratory Billing: How Pathology Groups Can Stop Losing Revenue

Running a pathology group or diagnostic laboratory is challenging enough – but revenue cycle challenges make it even harder. If your lab claims are being denied due to missing prior authorizations, incorrect CPT codes, or “medical necessity not met” errors, you’re not alone. 

Laboratory billing is one of the most complex areas of U.S. healthcare revenue cycle management (RCM). With payers tightening scrutiny on molecular and genetic testing, expanding prior authorization requirements, and rolling

Deloitte Survey Indicates Now Is a Great Time to Outsource Medical Coding Image

Deloitte Survey Indicates Now Is a Great Time to Outsource Medical Coding

As the challenges in the U.S. healthcare landscape continue to become more complex, healthcare revenue cycle leaders across hospitals, health systems, and physician groups will benefit from looking at new ways to outsource medical coding. From the long-term impacts of new federal legislation, to workforce shortages and the rise of AI-enabled payers, U.S. healthcare providers can no longer look at medical coding outsourcing as an option – it’s a strategic necessity. 

Instead, it should be leveraged as an opportunity to tap into skills, resources, and services that aren’t available internally. This perspective will be critical as competition for specialized skills increases and the tech arms race progresses. Outsourcing medical coding services should be a foundational pillar for building the kind of multidimensional sourcing ecosystem that this survey from Deloitte addresses [1].

To help you and your team better understand the role that medical coding outsourcing can play at your organization, we’ve put together the highlights from the survey for your review.  By prioritizing the benefits and strategies addressed below, you can transform your medical coding operations from a cost center into a strategic asset. 

Maturing Your Approach to Medical Coding Outsourcing

For U.S. hospitals, health systems, and physician groups, outsourced medical coding services are becoming a cornerstone of revenue cycle strategy. Delivery models are becoming more sophisticated and beginning to emphasize relationships based on value over simple cost savings. 

While some respondents to the survey reported beefing up internal operations, investments in external partnerships were also featured heavily, with only a few respondents planning a decrease. Back-office functions continue to be outsourced at higher rates, but organizations are increasingly focused on creating greater value from core competencies. For revenue cycle leaders considering medical coding outsourcing, this trend is worth paying attention to. It highlights the fact that a strategic approach to medical coding outsourcing can be a decisive factor in achieving operational agility and securing skilled talent, and more than just a cost cutting measure.

The Deloitte survey highlights this shift away from a focus on cost savings in outsourcing.  This evolving perspective redefines the value proposition of outsourced services – moving the focus from sourcing inexpensive labor to acquiring high-value capabilities, like specialization in the healthcare revenue cycle. 

Revenue cycle leaders should now prioritize improved access to talent, enhanced service quality, and greater agility, in addition to spend optimization. While cost reduction will remain a consideration in medical coding outsourcing, the strategic priority must be on discovering continuous opportunities for creating incremental value. This means working with your revenue cycle vendor to access talent, integrate advanced technology, and enhance core capabilities.

Access the Distinct Value of Back-Office Outsourcing

The survey reveals that back-office outsourcing remains a foundational component for many organizations. These functions are being outsourced at elevated rates, allowing businesses to concentrate on their primary competencies while benefiting from a provider’s specialized knowledge to continue driving operational efficiency. By focusing on back-office outsourcing, U.S. healthcare revenue cycle departments can access benefits including:

  • Enhanced access to medical coding talent
  • Improved quality and performance
  • Ability to gain access to new capabilities

Medical coding services, a critical back-office function, are prime candidates for this model. Revenue cycle departments should adopt a comprehensive sourcing strategy and integrate outsourced medical coding services as an integral component of their overall operating model. This approach moves beyond a piecemeal solution, positioning the department to capture the full benefits of a strategic partnership.

Prioritizing Value-Based Relationships and Addressing Challenges in Your Revenue Cycle Outsourcing Strategy

To maximize the impact of your investment in a medical coding outsourcing partner, focus on vendors who are experienced in healthcare and who can provide a relationship based on value. 

Deloitte recommends collaborating with your service provider to explore new areas of creating this value. 

Keep in mind, many organizations encounter challenges in their outsourcing programs, many of which stem from internal management capabilities. The survey points out key internal obstacles to success, including: 

  • An inadequate approach to organizational change management
  • Poor integration of vendor services
  • An inability to track and report on realized benefits
  • Insufficient financial oversight

To get ahead of these challenges, revenue cycle leaders need to bolster their internal management capabilities and apply them directly to outsourced services. This includes areas of competency including: 

  • Value management
  • Performance oversight
  • Effective vendor relations

To maximize value from an outsourcing program, your leadership should reach out to embrace strategic measures in their outsourcing program. This includes defining a comprehensive sourcing strategy and integrating outsourcing as a fundamental part of your global operating model. In the world of outsourcing medical coding, this translates into a need for a well-defined strategy that considers the impact on the entire revenue cycle function.

Future-Readiness Hinges on Talent Sourcing

To prepare for the future, revenue cycle departments must leverage external partnerships to manage complexity and deliver results. The possibilities of the modern talent pool are expanding, and organizations are adjusting their sourcing approach to gain flexibility, efficiency, and access to specialized skills.

No executive from the Deloitte survey reported relying exclusively on internal employees for their talent requirements. For a provider considering a medical coding outsourcing partner, this means looking for a vendor with a sophisticated approach to talent management, beyond simple staff augmentation. Providers should look for opportunities to collaborate across internal departments, developing new competencies, and potentially recruiting personnel with a broad experience of managing diverse talent models. A well-executed medical coding outsourcing program can be a key part of this overall talent strategy.

Supercharge Your Medical Coding Outsourcing Strategy With AI

The Deloitte survey highlights the importance of a fresh strategic perspective on your outsourcing practices. This type of strategic partnership can help your organization access a deeper pool of skilled medical coders, enabling improved accuracy and reduced claim denials.

These benefits are greatly enhanced when working with a partner that leverages AI solutions on top of their deep experience in healthcare. At 3Gen Consulting, our AI coding platform, CodeGen-i, combines the speed and efficiency of AI-assisted coding with the assurance of certified coder review. Every chart is validated by an experienced coding professional, so clients gain both productivity and a higher level of accuracy. To learn more about how we can partner as a part of your future-ready outsourcing strategy, contact us today.

 

References

[1] Deloitte, “Global Outsourcing Survey 2024,” 5 February 2025. Available: https://www.deloitte.com/content/dam/assets-zone3/us/en/docs/services/consulting/2024/us-global-outsourcing-survey-2024-report.pdf.

RADV Audits & Risk Adjustment Coding in 2025- How Medicare Advantage Plans Can Protect Revenue Image

RADV Audits & Risk Adjustment Coding in 2025: How Medicare Advantage Plans Can Protect Revenue

RADV audits just got real. In 2025, Medicare Advantage (MA) plans are facing the true financial impact of inaccurate or incomplete risk adjustment coding.

With CMS enforcing stricter RADV extrapolation rules and intensifying HCC validations, the message is clear: risk adjustment compliance and accurate HCC capture are not optional.

For Medicare Advantage plans, ACOs, and risk-bearing provider

September 2025 AI in Healthcare Revenue Cycle- The Big Opportunity in Medical Billing Accounts Receivable

AI in Healthcare Revenue Cycle: The Big Opportunity in Medical Billing Accounts Receivable

A recent HFMA study shows that hospital CFOs see revenue cycle – especially medical billing accounts receivable and denials management – as the biggest area of opportunity for AI [1]. This raises a key question: what do revenue cycle leaders need to do to prepare? Considering the complexity of AI technology, choosing a good partner with “pre-AI” revenue cycle expertise is

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