Medicare's Comparative Billing Reports are a self-audit tool
Use your report to check 20 recent 99214 notes. Most providers will never need a Targeted Probe and Educate review, Medicare says.
Co-founder, JotPsych
You bill most medication visits as 99214, and a Medicare report compares your share with your peers' shares. Treat the report as a comparison, not a denial.
| Program | What Medicare does | What you do |
|---|---|---|
| Comparative Billing Report | Compares your billing with peers in your state and the nation | Check your notes as a self-audit |
| Targeted Probe and Educate | Reviews 20 to 40 of your claims a round, for up to three rounds | Send records, then use the education |
Medicare's compliance program pages describe both programs. Your self-audit checks the same kind of note that a Targeted Probe and Educate round reviews.
- Read what the report compares. Your Comparative Billing Report (CBR) sets your billing beside peers in your state and the nation. The Centers for Medicare & Medicaid Services (CMS) calls the report a self-audit tool on its compliance program page, and the report teaches Medicare's coverage, coding, and billing rules.
- Pull 20 recent 99214 notes. Twenty is the low end of a round of Targeted Probe and Educate (TPE) review. Take notes from several weeks and from each clinician who bills 99214.
- Check each note for moderate medical decision making or 30 minutes. Without moderate medical decision making or 30 minutes of total time, your note doesn't support a 99214, per CMS's office visit guide. Calling a patient "stable" who isn't at goal can limit the visit to 99213 when you code by medical decision making, per our 99214 note guide.
- Add a missing item to your note template. Notes built from one template leave out the same items, such as your total time, so add the missing item once and your next notes include it.
From Medicare's Targeted Probe and Educate page and information sheet. A review ends after any round that finds your claims compliant, and errors that last past round 3 go to the Centers for Medicare & Medicaid Services.
How a TPE review runs
Your Medicare Administrative Contractor (MAC) picks providers for TPE from claim data, such as high error rates. You'll get a letter first. Your MAC then reviews 20 to 40 of your claims with their records.
Education follows each round. CMS's TPE information sheet gives you at least 45 days after each round to make changes. Many errors are simple, such as a missing signature. Check signatures before you send records. CMS's next steps for errors that last past round 3 can include a review of every claim before payment.
JotPsych's Audit Center compares each billed code with the code its AI recommends, and marks Match or Mismatch.
Book 15 minutes- Centers for Medicare & Medicaid Services, Medicare Fee-for-Service Compliance Programs, page last modified July 28, 2026: Comparative Billing Reports. Read October 5, 2026.
- Centers for Medicare & Medicaid Services, Targeted Probe and Educate, page last modified March 4, 2026: most providers will never need TPE, rounds of 20 to 40 claims, and referral to CMS after three rounds. Read October 5, 2026.
- Centers for Medicare & Medicaid Services, What is Targeted Probe and Educate?, information sheet: the letter, the rounds, the 45 days after each, and simple errors such as a missing signature.
- Centers for Medicare & Medicaid Services, MLN006764, Evaluation and Management Services, May 2026: 99214 by moderate medical decision making or 30 minutes of total time.
- JotPsych, Med check note do's and don'ts for a 99214.