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Medicare Advantage fraud statistics track payment errors, excess spending and settlements, but those figures do not add up to a national fraud total. For a healthcare coder, clinician or finance employee, the useful connection is between a diagnosis, the payment it produced and what the company did after someone challenged it. An audit finding that never reached the payment file tells you more about a whistleblower case than a national percentage.
The national payment estimates do not answer how much Medicare Advantage paid for fraudulent claims. The Centers for Medicare & Medicaid Services measures payment errors. The Medicare Payment Advisory Commission estimates what Medicare spends above the cost of covering comparable beneficiaries in traditional Medicare. The Justice Department announces settlements over particular conduct.
Improper Medicare payment estimates measure errors, including overpayments and underpayments. Unsupported diagnoses dominate the overpayments in the Centers for Medicare & Medicaid Services’ fiscal 2025 Part C report, which examines payments made in calendar 2023.
in estimated gross Part C payment errors for calendar 2023, reported in fiscal 2025.
Approximately $19.20 billion in net payment errors.
Centers for Medicare & Medicaid Services, Part C Improper Payment Measure, fiscal 2025 results
The report lists $21.43 billion in overpayments. An unsupported diagnosis can increase what a plan receives even when the patient never had the condition.
The gross error rate was 6.09%, measured against $388.72 billion in Part C expenditures within the measure’s scope. Unsupported diagnoses accounted for 5.51% of those expenditures. The agency identifies overpayments when submitted condition categories lack medical-record support or the review supports a less severe condition.
Source: CMS, FY 2025 Part C Payment Error Rate Results, Table 1. Published rounded estimates.
Part C Improper Payment Measure, FY 2025 Payment Error Rate Results
Medicare Advantage overpayments in the Medicare Payment Advisory Commission’s March 2026 projection amount to $76 billion above what traditional Medicare would spend on comparable beneficiaries in 2026. That is a 14% difference measured against comparable fee-for-service spending.
The largest component is favorable selection, projected at $57 billion. People whose risk scores predict more spending than they actually incur disproportionately enroll in Medicare Advantage. The commission attributes another $22 billion to coding intensity after the coding adjustment the Centers for Medicare & Medicaid Services applies.
The older figure still circulating comes from the commission’s March 2025 projection: $84 billion, or 20%, for 2025. The commission attributes the lower projected difference for the following year primarily to the completed phase-in of the new risk model and newer data showing slower risk-score growth.
Medicare pays a Medicare Advantage plan a monthly amount for each member, adjusted for expected health care costs. Diagnoses feed the risk score that changes that amount. A count of coded conditions therefore measures something different from a count of bills for office visits.
A diagnosis can affect the plan’s payment even when it arrives through a retrospective chart review. The provider’s visit note, the vendor’s coding result and the plan’s submission to Medicare sit at different points in that process. A provider group may also share in the resulting revenue under its contract.
That creates an important question for anyone reading a risk-score comparison: how much of the measured sickness comes from the way the records are coded? A 2019 study in Health Management, Policy and Innovation compared national Medicare Advantage and fee-for-service samples from 2010 through 2014. It measured the populations using both the condition categories that drive payment and an alternative grouping of diagnoses that does not. The alternative measure substantially reduced the apparent risk in the Medicare Advantage population, bringing it close to the fee-for-service population, and the authors found evidence that plans may be using more intensive coding to drive up risk scores and payment rates.
The population looked much sicker under the measure that paid the plans. For an insider accustomed to risk-score targets, that is a reason to examine how the diagnoses entered the payment system.
Health risk assessments and their linked chart reviews generated an estimated $7.5 billion in 2023 risk-adjusted payments from diagnoses found on those records alone, according to an October 2024 review by the Office of Inspector General at the Department of Health and Human Services. Those diagnoses appeared on no other 2022 service records.
In-home assessments and their linked reviews generated almost two-thirds of that amount. Twenty companies generated 80% of the overall estimate. The inspector general singled out diabetes and congestive heart failure among the conditions driving these companies’ assessment-related payments.
The inspector general identified a concrete clinical question: diagnoses without other follow-up visits, tests, procedures or supplies could reflect inaccurate diagnoses or serious conditions for which members did not receive needed care. Taxpayers fund the unsupported diagnoses, while members may go without the care those diagnoses call for.
The home-visit payment pathway matters because the plan or its vendor often arranges the assessment, rather than the member’s usual provider. The organization receiving the additional payment can also control the process producing the diagnosis. The patient’s medical record supplies the comparison that the revenue report cannot.
Medicare Advantage False Claims Act settlements put a price on specific allegations. The 2026 settlements show how pressure to add diagnoses and decisions to leave unsupported codes in place can become major cases.
Kaiser Permanente agreed to pay $556 million in its January 2026 settlement. The government alleged that Kaiser pressured physicians to add diagnoses after visits and linked financial incentives to diagnosis goals, despite internal warnings.
Aetna’s March 2026 settlement totaled $117.7 million. It resolved allegations that the plan used chart reviews to add diagnoses without withdrawing unsupported ones, and submitted or failed to delete inaccurate morbid-obesity codes. The same review that found more revenue also found reasons to return it.
Cigna’s September 2023 national resolution totaled $172,294,350. It addressed allegations about chart reviews, home visits and morbid-obesity diagnoses. The $37 million home-visit settlement announced by the Middle District of Tennessee was part of that national amount. Adding the district announcement to the national announcement would count the home visits twice.
The district announcement also records Cigna’s factual admissions. Cigna acknowledged submitting diagnoses where assessment forms lacked corroborating clinical information and did not reflect the testing needed to make the diagnosis for the first time. The admission tells us what was wrong with the diagnoses behind the check.
Independent Health’s December 2024 settlement required $34.5 million in fixed payments and up to $63.5 million in contingent payments. The department based the settlement on the company’s ability to pay. The government alleged that Independent Health created DxID to search records and obtain additional diagnoses for itself and other plans.
Even within Medicare Advantage, diagnosis coding is only part of the enforcement picture. Independence Blue Cross’s 2020 settlement for $2.25 million concerned allegedly inflated cost data in plan bids. That amount belongs to a different payment input from a home assessment or a chart review.
Whistleblower rewards attach to the recovery in the case. Cigna’s announcement assigned an $8.14 million reward to the home-visit allegations within its broader resolution. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.
The strongest connection between the statistics and an insider’s experience is what happened after a review found a problem. In the government’s complaint against Anthem, the alleged choice was explicit:
Instead, Anthem used chart reviews only to submit additional diagnosis codes to CMS while turning a blind eye to negative results where chart reviews could not substantiate the diagnosis codes that Anthem had previously submitted to CMS.
Government’s allegation, United States v. Anthem, Inc., complaint
The complaint alleged that Anthem could have compared previously submitted diagnoses with the vendor’s review results for the same patients and visits. According to the complaint, Anthem did not run that comparison, despite having programmers capable of doing it. The alleged one-way review process left a trail in the data: additions went forward while unsupported earlier codes remained.
The whistleblower in the Sutter case alleged that audit corrections went into the billing side of the electronic record while diagnoses remained in the medical record used for Medicare submissions. In that account, the correction appeared in the wrong file. Management had allegedly been told that a billing-only change would leave the Medicare data wrong.
These are decisions a national rate cannot explain. A coding reviewer may know which findings were discarded. Finance may know which corrections threatened forecast revenue. A clinician may know why the record contradicted the submitted condition. Their knowledge connects the number to the business that produced it.
If you saw unsupported diagnoses survive a review, or corrections stop before they reached Medicare, speak to one of our Whistleblower Experts about the decisions behind those numbers. We work with you to connect the clinical record, the payment data and what management knew, bringing in Medicare Advantage fraud whistleblower lawyers to build your strongest case. We stay with you as partners throughout the case.