Downcode Radar · new · free scan

Payers are quietly paying your 99214s as 99213s.

One level down costs a median $37 per office visit and up to $77 per ED visit in published commercial rates. Since October 2025 the biggest payers run automated downcoding programs. Your own 835 remittance files already prove what it is costing you. Drop them in and see, free. Nothing uploads.

Parsed on your device No PHI leaves your browser No BAA needed Verify it in DevTools
Your 835 already says it · line from a synthetic sample
SVC*HC:99213:25*220*44**1*HC:99214~
CAS*CO*150*34~
SVC06 says what you billed (99214). SVC01 says what they paid (99213). CARC 150 is the payer's own reason code: "Payer deems the information submitted does not support this level of service." Most practices never read this field. The radar reads every line.
This is not a theory. It is policy, and regulators are reacting.

Automated downcoding went mainstream in 2025. The pushback started in 2026.

Oct 1, 2025
Cigna's R49 policy takes effect
"Evaluation and Management Coding Accuracy" adjusts CPT 99204–99205, 99214–99215, and 99244–99245 down one level when Cigna decides the claim data does not support the billed level. The lower level is paid first; recovering the difference requires submitting the full record. Source: Cigna reimbursement policy R49.
2025
Aetna expands, the AMA pushes back
Aetna expanded its vendor-operated E/M downcoding program to its commercial states (Louisiana excepted). The AMA formally demanded Cigna rescind its policy in an August 2025 letter, and AMA policy states it is "never appropriate to downcode claims automatically or without a review of the medical record." By late 2025, one specialty society counted more than a dozen plans with active or proposed downcoding programs.
Mar 13, 2026
Maryland fines Cigna and orders it to stop
The Maryland Insurance Administration issued a consent order (Case No. MIA-2026-03-009) with an $80,000 penalty, ordering Cigna to cease automatic reduction of billed E/M code levels in Maryland. Indiana signed HEA 1271, one of the nation's most comprehensive anti-downcoding laws, the same month. MGMA's 2026 Regulatory Burden Report ranks Medicare Advantage automatic downcoding the #4 burden facing medical groups.

Sources: Cigna reimbursement policy R49 and Cigna provider newsroom; AMA "Payer E/M downcoding programs: what you need to know"; Maryland Insurance Administration Consent Order MIA-2026-03-009; Indiana HEA 1271; MGMA Regulatory Burden Report, April 2026. Cigna has paused R49 application for certain California fully insured plans pending regulator review.

What one level down actually costs

The per-visit loss, from real published contract rates.

These are live medians from Reddenda's benchmark index of federal Transparency in Coverage filings: the median state-level difference between each E/M level and the level below it, across all 52 jurisdictions.

Downcode patternMedian loss per visitPublished rates behind it
99214 paid as 99213Established office visit, the workhorse code$37170,449
99215 paid as 99214Established office visit, highest level$53168,914
99204 paid as 99203New patient office visit$62141,993
99205 paid as 99204New patient office visit, highest level$50139,251
99285 paid as 99284Emergency department, level 5$64114,383
99284 paid as 99283Emergency department, level 4$77111,953
99223 paid as 99222Initial hospital care$58123,399
99233 paid as 99232Subsequent hospital care$42132,077

Live medians of state-level median differences, Reddenda benchmark index of federal Transparency in Coverage machine-readable files, all 52 jurisdictions, computed July 2026. Medicare reference point: under the 2026 Medicare Physician Fee Schedule, a 99214 downcoded to 99213 forfeits $40.42 per visit at the national non-facility rate. Individual state and payer amounts vary; figures are market benchmarks, not any single contract. Documented reimbursement opportunity is modeled, not guaranteed.

How it works

Three steps. Your files never leave your machine.

STEP 1

Drop your 835 files

Export the electronic remittances (835 / ERA) from your clearinghouse or PM system and drop them in. Parsing runs in your browser. Patient names, member IDs, claim numbers, and exact dates are stripped on your device, with a visible counter of everything that was stripped.

STEP 2

The radar reads what payers wrote

Three detection tiers, each labeled by its evidence: downcodes the remittance itself documents, reductions the payer signaled with its own adjustment codes, and lines paid at the lower level's market rate. The evidence tier is always visible.

STEP 3

Dollarize, rank, appeal

Every flag is benchmarked against real published contracted rates in your state and ranked payer by payer. Documented and signaled flags can become a first-level appeal letter in one click, citing the remittance evidence and the right appeal framework for the plan type.

Documented by the payer

The remittance says it outright

When a payer adjudicates a different code than you billed, the 835 standard provides for reporting your submitted code alongside the paid code (per X12 guidance, the SVC06 field). Billed 99214, paid 99213, in the payer's own file. This is the strongest tier: the evidence is theirs.

Payer signaled

The reason code admits it

CARC 150: "Payer deems the information submitted does not support this level of service." CARC 186, RARC N22 and M85 likewise signal level-of-service changes and E/M review. The AMA's own downcoding guidance lists these exact codes as the tells.

Statistical pattern · review candidate

Paid at the lower level's rate

The code was left unchanged, but the allowed amount sits within 6% of the next lower level's state market median while at least 12% below the billed level's median. Labeled a review candidate, never proof: verify these against your own fee schedule first. Thresholds and sample sizes are always disclosed.

Privacy by architecture, not by promise.

Your 835 files are parsed on your device and never uploaded. Only two things ever leave the page: the state and CPT codes needed to fetch the market benchmark, and, if you click the AI features, de-identified aggregate figures. That is the whole list.

  • Open DevTools and watch the network tab during a scan.
  • Turn wifi off after the page loads: parsing still works.
  • No PHI transmitted, so no BAA is needed. We say "no PHI leaves your browser," never "HIPAA certified."
  • Appeal letters use bracketed placeholders for claim numbers; your worklist export with claim numbers is generated on your machine and stays there.
What the privacy counter looks like after a scan
Patient names stripped locally10
Member IDs stripped locally10
Claim numbers kept on device20
Exact dates reduced to year21
Files uploaded to Reddenda0
The legal backing

Every appeal stands on verified authority.

Downcode Radar's appeal letters cite the frameworks below, matched to the plan type. Every citation was verified against the primary source. Regulatory context, not legal advice.

29 CFR 2560.503-1 A downcode is an appealable adverse benefit determination under ERISA
Under the ERISA claims-procedure regulation, a decision to pay a claim only in part meets the definition of an adverse benefit determination. That triggers the claimant's right to at least 180 days to appeal, a full and fair review, the specific reason for the determination, and copies of the documents and internal guidelines the payer relied on. If the plan fails to follow compliant procedures, remedies can be pursued as if administrative appeals were exhausted.
Why it matters here: for employer-sponsored plans, the payer must explain the documentation basis of a downcode on request. The radar's letters request exactly that.
45 CFR 147.136 The ACA extends ERISA-grade appeal rights beyond ERISA plans
The ACA's internal claims and appeals rules apply the same adverse-benefit-determination framework to non-grandfathered individual and insured group coverage, and entitle claimants to diagnosis and treatment codes and their meanings on request.
Why it matters here: appeal rights on payment reductions are not limited to self-funded employer plans.
42 CFR Part 422, Subpart M Medicare Advantage: level-of-service refusals are appealable organization determinations
In Medicare Advantage, a plan's refusal to pay for services in whole or in part, including the type or level of services, is an organization determination subject to the MA reconsideration and appeal process. CMS has also finalized rules barring purely automatic adverse medical-necessity decisions without appropriate review. MGMA's 2026 Regulatory Burden Report ranks MA automatic downcoding the #4 regulatory burden.
Why it matters here: the radar's letters cite the MA framework for MA plans, never ERISA. The plan framework is selected per letter.
AMA / CMS, 2021 E/M levels are set by medical decision making or time
Since January 1, 2021, office and outpatient E/M visits are leveled by medical decision making or total time, and CMS confirms the MDM-or-time framework now applies to most E/M families. A downcode is a claim that your documentation does not support the billed level; the 2021 guidelines are the standard the record is measured against.
Why it matters here: the appeal asks the payer to identify the specific documentation-based rationale under the current guidelines.
CARC 150 / 186 · RARC N22 / M85 The payer's own remittance codes identify downcoding
The official code texts: CARC 150, "Payer deems the information submitted does not support this level of service." CARC 186, "Level of care change adjustment." RARC N22, "This procedure code was added/changed because it more accurately describes the services rendered." RARC M85, "Subjected to review of physician evaluation and management services." Per X12 guidance, a payer adjudicating a different code than billed reports the submitted code on the 835 (SVC06).
Why it matters here: these exact codes are what the radar reads, on every line, in files you already receive.
State law Indiana, Arkansas, Virginia, Texas and others are regulating downcoding
Indiana HEA 1271 (signed March 2026) enacted comprehensive downcoding protections. Arkansas Act 136 of 2025 forces disclosure of downcoding practices. Virginia Code 38.2-3407.15 requires carriers that routinely downcode to disclose that practice in provider contracts. Texas TDI rules entitle contracted providers to the payer's downcoding policies and coding methodologies on request, and Texas prompt-pay penalties (Tex. Ins. Code 1301.137 and 843.342) are among the strictest in the country. Maryland's insurance regulator ordered a national payer to stop automatic E/M downcoding in March 2026. Georgia SB 444 will bar coverage decisions made solely by AI systems effective January 1, 2027.
Why it matters here: the regulatory direction is disclosure and record review before reduction. Documented downcodes are exactly what these laws exist to police.
Built for the people who work the remits

Every book of business has downcodes hiding in it.

Billing companies and RCM firms

You are paid on collections, so every silent downcode cuts your revenue too. Batch-drop a client's 835s, hand them a ranked downcode report their EHR cannot produce, and work the appeals from the on-device worklist export with claim numbers intact. Be the firm that caught what the last firm missed.

Independent practices

One biller, no time, and Cigna has been paying your 99214s at odd amounts since October 2025. Export one month of ERAs, drop them in, and see your number in about ten minutes. Free to scan, nothing uploads, no BAA conversation with anyone.

Specialty groups and MSOs

High E/M volume multiplies every per-visit loss, and multi-state books need per-state benchmarks. The radar benchmarks each line against its own state's published rates, all 52 jurisdictions, and rolls patterns up payer by payer for your next payer meeting.

The honest comparison

They detect downcoding too. Here is what only Downcode Radar does.

We checked seven downcoding and underpayment products in July 2026. Several detect E/M downcoding well. Every one is enterprise, sold through a demo, and needs your claims data in their cloud. Here is the honest picture, side by side.

Scroll to compare →
What it takes to catch your downcodes ★ YOU RUN ITDowncode RadarReddenda MD ClarityRevFind AnomalyManage Rivet WaystarAltitudeAI
Detects E/M downcoding ~variance ~DRG level
Parsed on your device, no PHI upload
Self-serve, no sales demo
Free to start
No integration or IT project EDI / EHR
No BAA, your records stay with you
Benchmarked to published market rates public market ~your contract ~your contract ~your contract ~your contract
Flat fee tied to results, never a cut of recovery flat USD quoted quoted quoted quoted
One-click appeal letter ~recovery team in-suite
Runs across a whole book by call
Yes ~ Limited or differently scoped No

Compiled July 2026 from each vendor's public product and pricing pages (MD Clarity RevFind, Anomaly Manage, Rivet, Waystar AltitudeAI; Adonis and Experian Contract Manager were also reviewed and fit the same enterprise pattern). Partial marks reflect a narrower or differently scoped capability, not its absence; several of these tools detect downcoding well. "No BAA" and "no PHI upload" describe Downcode Radar's on-device architecture. Competitors ingest claims and remittance data through EDI or EHR integrations, so a business associate agreement applies. This compares publicly stated capabilities and is not an endorsement; details change, so verify against each vendor.

Free to see it, priced with you on a call

See one real finding free. Unlock the rest on a short call.

See one real finding free: your biggest downcode pattern and one documented reimbursement opportunity, benchmarked to your state, no PHI required. To unlock the full per-CPT, per-payer breakdown, one-click appeal letters, and your counteroffer, we walk your own data with you and price it on a short call.

See it free
Free scan on your own 835s, parsed on your device, no account needed to try the demo
  • Parse and detect on your device
  • All three detection tiers, ranked by payer
  • Live state benchmarks, all 52 jurisdictions
  • The E/M ladder view of your biggest pattern
Scan a remittance free →
Work the whole book
The full per-CPT, per-payer breakdown and appeals, walked with you on a call
  • One-click appeal letters on documented and signaled flags, plan-framework aware
  • Worklist export with claim numbers, generated on your device
  • De-identified CSV and print summaries
  • AI pattern read across your scans
  • Full modules: Claim Scrubber, Recovery, Renewals
Book your discovery call →
Close the loop
Appeals recover the downcodes; the Leverage Memo renegotiates the rate itself
  • Signable counteroffer anchored to your state's 90th percentile
  • Built from the payer's own published rates
  • Full per-CPT RateScore and P50-to-P90 rate map
  • Multi-NPI and billing-company terms: scoped on the call
Apply for a discovery call →

Your structure depends on your NPIs, payer mix, and the opportunity in your own data, so we price it with you on a short call. Documented reimbursement opportunity is modeled, not guaranteed.

EKRA posture. Every Reddenda fee is a flat US dollar amount tied to verified results, never a cut of your recovery. We never charge a percentage of collections, recoveries, or rate increases, and never tie a fee to a deal's dollar value. Every dollar you recover is yours.
Honest numbers. Detection evidence is the payer's own remittance. Dollar figures are modeled gaps to your state's published market benchmarks, not your contracted rate, and are documented reimbursement opportunities, modeled and not guaranteed.
Straight answers

Questions billers actually ask.

Where do I get my 835 files?
Every clearinghouse and most PM systems export them: look for "835," "ERA," or "electronic remittance advice" in your reports or downloads area (Availity, Waystar, Office Ally, and PM systems all offer this). Export a month, drop the files in. If you only have paper EOBs, the radar needs the electronic 835; ask your clearinghouse to enable ERA delivery, which most payers support.
Is "nothing uploads" actually true?
The 835 files are parsed entirely in your browser and are never transmitted. Two things do leave the page: the state and CPT codes needed to fetch the benchmark, and, only if you click the AI features, de-identified aggregate figures. You can verify all of it in your browser's network tab, and parsing keeps working with wifi off. That is why no BAA is needed: our servers never touch your files.
My contracted rates are not the state median. Do the dollar figures apply to me?
The dollar figures are market benchmarks: the gap between what was allowed and what your state's published median and 90th percentile pay for the billed code. They are context, not your contract. The detection does not depend on them for the documented and signaled tiers: those stand on the remittance itself. For statistical-pattern flags, always verify against your own fee schedule first; the tool says so on every such flag.
Are not some downcodes legitimate?
Yes. If the documentation genuinely does not support the billed level, the reduction can be proper, which is why the radar labels evidence tiers instead of declaring guilt, and why the appeal letter asks the payer for the specific documentation-based rationale and asserts the 2021 MDM-or-time guidelines your record is measured against. AMA policy objects to downcoding done automatically, without record review, which is what the 2025 payer programs do.
What will I actually recover?
We do not promise recovery amounts, and you should distrust anyone who does. For market context only: a 2024 Premier survey found 54.3% of fought private-payer denials were ultimately overturned, after an average of three review rounds, and KFF found fewer than 1% of denials are appealed at all. The radar's job is to make the evidence and the letter nearly free, so the math of fighting changes.
Which plans do the appeal letters work for?
The letter adapts its appeal-rights framework to the plan type: conditional ERISA language for commercial coverage, the organization-determination framework for Medicare Advantage, and state managed-care processes for Medicaid plans. The plan type is inferred from the remittance filing code and you can override it before generating. Every letter is a draft for your review, not legal advice.
Your next step

Prove it on your own remittances first.

See one real finding free: scan a month of 835s on your device and get your biggest downcode pattern and one documented reimbursement opportunity, no PHI required. Then unlock the full per-CPT, per-payer breakdown and your counteroffer on a short call. Your structure depends on your NPIs, payer mix, and the opportunity in your own data, so we price it with you on the call.

Book your discovery call → Want to see it first? Scan a remittance free. Documented reimbursement opportunity is modeled, not guaranteed.
Methodology, sources, and disclosures. Benchmarks are per-CPT percentiles of real published commercial contracted rates by state, from Reddenda's normalized index of federal Transparency in Coverage machine-readable files (45 CFR 147.210 and 147.212 require payers to publish and refresh them monthly), alongside the 2026 CMS Physician Fee Schedule and the public NPI Registry. The per-visit loss table shows live medians of state-median differences across 52 jurisdictions, computed July 2026; scope of the underlying index: 314M+ federal rate records, 500+ payers, 50 states, 9.2M+ NPIs, the live scope of the index:. Detection tiers: documented (the 835 reports a different submitted code, SVC06, than the paid code, SVC01, per X12 guidance), signaled (CARC 150 or 186, RARC N22 or M85), statistical pattern (allowed amount within 6% of the next lower level's state median and at least 12% below the billed level's median; review candidates, not proof). Cited facts: Cigna reimbursement policy R49 (effective October 1, 2025) and Cigna provider newsroom; Maryland Insurance Administration Consent Order MIA-2026-03-009 (March 13, 2026); AMA, "Payer evaluation and management (E/M) downcoding programs: what you need to know" (2022); MGMA Regulatory Burden Report (April 2026); Premier Inc. claims-denial survey (March 2024); KFF analysis of 2024 HealthCare.gov transparency data; 2026 Medicare PFS national non-facility amounts; Indiana HEA 1271; Arkansas Act 136 of 2025; Va. Code 38.2-3407.15; Texas TDI rules and Tex. Ins. Code 1301.137 and 843.342; Georgia SB 444 (effective January 1, 2027). All dollar figures are documented reimbursement opportunities or market benchmarks, modeled and not guaranteed; actual outcomes depend on payer response, contract terms, documentation, and appeal outcome. No PHI leaves the visitor's browser; Reddenda is not a law firm and nothing here is legal advice. © 2026 Reddenda / TwinFlame Group.