20 New Audit Topics: What Providers Should Know About CMS RAC Updates

Sarah Brainard
,
Vice President of Product, Self Pay
November 12, 2025
OA Editorial Team
,
Publisher
November 12, 2025
Medicare audit readiness tools

In August of this year, the Centers of Medicare & Medicaid Services (CMS) approved 20 new Recovery Audit Contractor (RAC) topics, officially expanding the range of issues subject to medical review. These new audit topics signal an increase in expected audit activity for hospitals. 

To prepare, providers should start by reviewing these topics to better understand how they will be affected. Then, it’s time to take a proactive approach to audit readiness and denial prevention. Ask yourself: Is your team prepared to respond quickly while maintaining full compliance?

What the New CMS RAC Topics Mean

CMS must approve all audit topics before RACs can begin conducting audit reviews to identify improper Medicare payments. RACs cannot audit outside their approved topic areas. 

Topics are typically based on data analysis showing high error rates and patterns of incorrect billing. Organizing audits by approved topics helps ensure audits are targeted and systematic rather than random. 

By approving 20 new audit topics, CMS has authorized RACs to review a new universe of issues. Some reviews are designated as automated, others as complex, but either way, the upcoming audit cycle will likely be more intense for providers offering services under these topics.

Examples of Newly Approved RAC Topics

Examples of Newly Approved RAC Topics

As per the offical CMS website, the 20 new audit topics include:

Issue Name Review Type Provider Type MAC Jurisdiction
0121-Destruction of Premaliganant Lesions: Excessive Units Automated Professional Services All A/B MACs
0132-Evaluation and Management Same Day as Admission to a Nursing Facility: Unbundling Automated Professional Services All A/B MACs
0143-Vitamin D Assay Testing: Medical Necessity and Documentation Requirements Complex Inpatient Hospital; Outpatient Hospital JE, JF
0162-Computerized Tomography Coronary Angiography: Medical Necessity and Documentation Requirements Outpatient Hospital All A/B MACs
0176-Annual Wellness Visit: Incorrect Coding Complex Professional Services All A/B MACs
0197-Immunosuppressive Drugs: Medical Necessity and Documentation Requirements Complex DME Physician/DME Supplier All DME MACs
0207-Spinal Cord Neurostimulation: Medical Necessity and Documentation Requirements Complex Ambulatroy Surgical Center (ASC); Outpatient Hospital; Professional Services All A/B MACs
0046-Durable Medical Equipment Rentals - Multiple Billing within the Same Month Automated DME Physician/DME Supplier All DME MACs
0066-Positive Airway Pressure Devices for Treatment of Obstructive Sleep Apnea: Medical Necessity and Documentation Requirements Complex DME Physician/DME Supplier All DME MACs
0078-Cardiac Pacemaker: Medical Necessity and Documentation Requirements Complex Ambulatory Surgical Center (ASC); Outpatient Hospital All A/B MACs
0079-Ventilators: Medical Necessity and Documentation Requirements Complex DME Physician/DME Supplier All DME MACs
0102-Home Use of Oxygen: Medical Necessity and Documentation Requirements Complex DME Physician/DME Supplier All DME MACs
0116-Modifiers TC and PC: Incorrect Coding Automated Professional Services All A/B MACs/td>
0112-Monthly Capitation Payment for End-stage Renal Disease: 4 or more Visits Per Month Automated Professional Services All A/B MACs

Source: Centers for Medicare and Medicaid Services

As CMS rolls out these new topics, providers should expect a rise in audits, additional documentation requests (ADRs) and, unfortunately, denials—especially for automated reviews. 

Without adequate preparation, audits can quickly lead to lost revenue and compliance risks. Hospitals should have documentation in order for relevant audit topics and a system in place for efficiently tracking audit responses. 

Simplify Audit Management with Office Ally’s Audit and Denial Tracker

Office Ally offers Audit and Denial Tracker, a centralized, cloud-based platform that helps providers monitor, manage and respond to audit and denial activity, all in one place.

Providers can track all active and denials (across multiple payers), manage documentation and maintain complete visibility into deadlines as the software guides each audit toward resolution. The software can also spot recurring denial trends after the fact, allowing for easy identification and correction of root causes.

As an authorized Health Information Handler (HIH), Office Ally can also automate federal audit replies and documents through esMD automatically. Full-cycle esMD integration means your team can skip the printing and paperwork entirely. Learn more about Audit and Denial Tracker and schedule a free demo.

Prepare Before the Next Letter Arrives

CMS’s new RAC topics are now in effect, and auditors have the green light to begin reviews. The next few months will bring increased RAC audit activity across nearly every provider type. Don’t let documentation gaps or missed deadlines put your reimbursements at risk.

Stay ahead of the surge by conducting internal reviews, organizing documentation and securing a reliable software solution to manage audits from start to finish. 

Gear up for the latest CMS audit cycle. Learn more about Office Ally’s Audit and Denial Tracker to manage the full lifecycle of audits and denials. 

Sarah Brainard

Vice President of Product, Self Pay

Sarah M. Brainard, an experienced healthcare professional at Office Ally, excels in innovation and efficiency. With a background in healthcare administration, she streamlines processes and enhances patient care nationwide. Leveraging technology, she spearheads initiatives to revolutionize healthcare operations for a brighter future.

OA Editorial Team

Publisher

We are Healthcare's Ally. We are here to support healthcare providers and payers with high-value software solutions that are reliable, affordable, and easy-to-use.

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