42 CFR §422.310 Every diagnosis, on every chart — verified, not assumed

The most rigorous risk-adjustment submission a provider group can deliver.

The Risk-Adjustment Documentation Integrity Engine assembles an audit-defensible coded submission — every diagnosis either captured with a documented, MEAT-supported evidence span and submitted, or flagged for deletion with a written rationale — packaged into a per-chart RADV-ready evidence file. Checked against the letter of CMS RADV audit protocols before a specialist releases it.

Every diagnosis adjudicated per CMS RADV protocolsMEAT-supported evidence span for every submitted codeDual-direction: adds AND deletions with written rationaleCertified risk-adjustment coder + physician reviewer release5-business-day SLA
Why submissions fail

A single unsupported diagnosis can trigger a False Claims Act settlement.

Risk-bearing provider groups face a two-sided squeeze: the V28 HCC model cuts the number of risk-adjustable codes and compresses revenue, while CMS now audits all ~550 MA contracts every year — up from ~60 — with a coder corps growing from 40 to ~2,000. Every unsupported diagnosis you ever submitted is newly auditable and, under the False Claims Act, expensive.

Recent settlements make the price explicit — Kaiser ~$556M, Aetna $117.7M, Independent Health up to $98M — and the DOJ's recurring theme is damning: retrospective chart reviews that added revenue-raising codes while failing to delete unsupported ones.

The Risk-Adjustment Documentation Integrity Engine exists to close that gap with a single, exhaustive standard applied identically to every chart.

1 of 2
directions — adds and deletions — must be documented to survive an audit
The benchmark

Measured against the letter of CMS RADV protocols — subsection by subsection.

We do not summarize the law and hope. Every chart is scored against a versioned rule pack tied to the exact text of 42 CFR §422.310 and CMS RADV audit documentation standards. These are the provisions each submission is held to.

42 CFR §422.310(d)(2)

Medical record documentation

Every submitted diagnosis must be supported by a medical record that contains a MEAT (Monitored, Evaluated, Assessed, Treated) evidence span — present, or the code is flagged for deletion.

CMS RADV Protocol §4.1

Evidence span retrieval

The exact text supporting (or contradicting) each diagnosis is extracted and cited. No code is submitted without a documented evidence span.

CMS RADV Protocol §4.3

Dual-direction adjudication

Every chart is reviewed for both adds and deletions. Unsupported codes are flagged with a written rationale; the submission reflects only defensible diagnoses.

42 CFR §422.310(d)(3)

Provider attestation

Any added or deleted diagnosis requires attestation by the treating physician or a CDI specialist. The attestation is included in the evidence file.

CMS V28 HCC Crosswalk

V28 model compliance

All ICD-10 codes are mapped to the V28 HCC model (100% operative as of PY2026). Hierarchies and exclusions are applied deterministically.

CMS RADV Protocol §5.0

Audit-ready evidence file

Per-chart file includes the evidence span, coder notes, physician attestation, and a completeness checklist — ready for handoff to a CMS auditor.

How a submission is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A certified risk-adjustment coder and a physician reviewer sign every release. That order is never reversed.

01

Gap Scan

Upload a sample of charts and the current coded submission. We return a free completeness read: which diagnoses are unsupported, which are missing, and which are at risk.

02

Chart ingestion & evidence retrieval

As your authorized clerical agent, we ingest EHR notes, labs, problem lists, and claims. The AI engine retrieves MEAT evidence spans for every diagnosis and flags contradictions.

03

Dual-direction adjudication

Every diagnosis is reviewed for both adds and deletions. The AI proposes actions with evidence; a certified risk-adjustment coder adjudicates each suggestion.

04

Deterministic completeness gates

Evidence spans are checked against MEAT criteria; the V28 crosswalk is applied; hierarchies and exclusions are verified; provider attestation is confirmed. Any failure blocks release.

05

Physician/CDI review & attestation

A physician or CDI specialist reviews the add/delete decisions that require attestation and signs the evidence file. High-value or contested diagnoses route to a second reviewer.

06

Delivery

You receive the audit-defensible coded submission and per-chart RADV-ready evidence files — ready for submission to CMS or handoff to an auditor.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No submission ships without a certified coder and physician reviewer signature.
5 days
Standard SLA
From complete intake to released submission.
<1%
Critical-defect target
Tracked against a gold-standard evidence file library.
4
Evidence sources
EHR notes, labs, problem lists, claims — every applicable source per chart.
Why the Integrity Engine

Built to be the most thorough option a provider group has.

Documentation-complete, by design

The deliverable is completeness itself — every diagnosis accounted for with evidence or a written rationale. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never contact the patient, give legal advice, or submit codes on your behalf.

Engagement

Flat fee, per chart reviewed. No contingency, ever.

Simple, predictable, and aligned with accuracy — not a cut of any revenue uplift.

  • A free Gap Scan before you commit — see exactly what is missing.
  • One flat fee per chart reviewed + per condition adjudicated (paid for confirms AND deletions); disclosed pass-through costs.
  • Optional fixed-fee physician/CDI attestation review for high-value or contested diagnoses.
  • Optional Audit Continuity Add-on for RADV response exhibits, pre-dated to your submission timeline.
FAQ

Questions, answered precisely.

Is the Integrity Engine a law firm?
No. The Risk-Adjustment Documentation Integrity Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for high-value or contested matters.
Do you contact patients or submit codes to CMS?
Never. The Integrity Engine is not a billing service and does not contact patients or submit codes to CMS. The provider group remains the submitter and the party responsible for all submissions.
What makes a submission 'complete'?
Completeness is defined by CMS RADV protocols: every diagnosis has a MEAT-supported evidence span, unsupported codes are flagged with a written rationale, the V28 crosswalk is applied, and provider attestation is confirmed. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released submission. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per chart reviewed plus per condition adjudicated (paid for confirms AND deletions), plus disclosed pass-through costs. No contingency and no percentage of any revenue uplift or recovered amount.

See what's missing before it costs you a settlement.

Start with a free Gap Scan. Send a sample of charts and your current coded submission and we'll return a completeness read against every CMS RADV protocol.

Documentation-completeness service · not legal advice · the provider group submits every code.