CMS’s March 2026 Guide:
Accuracy Points for Submitting Data

CMS’s March 16, 2026 Data Reporting Guide says complete, timely submission of audit data could earn full first-quarter accuracy points and that in early performance periods CMS will conduct audits.

By William Douglas Baker

Founding Editor

Within Medicare’s Wasteful and Inappropriate Service Reduction (WISeR) Model, the Centers for Medicare & Medicaid Services’ (CMS) March 16, 2026 Data Reporting Guide allots the measure called Accuracy of Determinations 16 of 25 quality points for the first quarter, and says participants “can earn full points on WISeR-2 through complete and timely submission of all data requested by CMS during the WISeR Quarterly Audit.” In early performance periods, it says, CMS “will conduct quarterly audits” but award WISeR-2 points “on a pay-for-reporting basis.”

The subject is a score, not a decision. CMS’s Payment Methodology says WISeR participants may earn payment for non-affirming a prior-authorization request “if it does not meet Medicare coverage criteria”, and that the determination “must not have been overturned on resubmission or by appeal”. CMS’s Provider and Supplier Operational Guide, version 7.0, defines a non-affirmation as “a preliminary finding” that a future claim “likely does not meet Medicare’s applicable coverage criteria”; CMS’s FAQ heads one answer “non-affirmations (denials)”. The Participant Guide, version 4.0, says Medicare Advantage plans and other payers use “advanced technologies, such as AI and machine learning,” and that WISeR “aims to apply similar tools in Medicare FFS”. That is design intent, not a finding about any decision.

Two papers, one date

CMS’s June 2025 draft Innovation Center Investment Plan (ICIP) said audit results indicating a high rate of improper determinations “would result in downward adjustments to the quality score”, and that its quality adjustment “would be critical in enforcing the defined quality metrics and minimizing any adverse incentives related to WISeR participation.” The draft’s cover reads “Last Modified: June 23, 2025.” It and the memo below are CMS records released under the Freedom of Information Act and posted by the Electronic Frontier Foundation.

The Office of the Actuary’s memorandum, “Wasteful and Inappropriate Service Reduction Model Estimate,” is dated June 23, 2025, and estimates the model “as proposed in the Innovation Center Investment Plan (ICIP) draft as of June 23, 2025.” It wrote: “The ICIP mentions a quality adjustment and while the determination of this adjustment has not yet been fully specified, it appears as though it would not significantly change the portion of savings the participants will receive.” The Office of the Actuary’s next sentence, in that June 23, 2025 memo estimating the draft design, read: “As a result, model participants will have an incentive to deny as many claims as possible.” The memo adds that the adjustment “has not yet been fully developed” and its impact “could be significantly different than our estimate”. Neither sentence says what any participant did.

The Sept. 16 hearing, as one press page renders it

A press page dated Sept. 16, 2026 from Senator Patty Murray’s office renders her questioning of Chris Klomp at a Senate Committee on Health, Education, Labor and Pensions hearing on his nomination as Deputy Secretary of HHS. As the page has it, she asks whether the contractors “make more money if they deny care? Just yes or no?” and he answers, “My understanding is no.” In the same rendering he later says: “My understanding is when they deny care, and if they do so inappropriately, there are significant financial penalties and that CMMI is carefully watching their performance and has the ability to terminate.” It has her saying the Office of the Actuary “literally said in a memo” the sentence quoted above, from its June 23, 2025 draft-design estimate. The committee’s page offers no transcript, as of Oct. 13, 2026.

What the first-quarter points rested on

The Participant Guide sets a WISeR payment rate of 25%, subject to further adjustments including the WISeR Discount and the quality adjustment: CMS reduces the regional benchmark by the Discount, applies the 25% rate, then applies the participant’s quality multiplier. The Participant Guide defines the Aggregate Quality Score (AQS) as the points a participant earned as a percentage of all quality points available, and its AQS table maps 85–100 to a multiplier of 100, 60–84 to 95, and below 60 to 90 percent.

The Data Reporting Guide, version 3.0, is dated March 16, 2026; the cms.gov model page did not list it on Oct. 13, 2026. Its Table 1 lists “WISeR-2: Accuracy of Determinations” with data source “CMS Audit” and basis “Pay-for-Reporting” for Performance Period 1 (PP1), which the Participant Guide dates Jan. 1 through March 31, 2026. Table 2 allots 25 points, 9 to WISeR-1 and 16 to WISeR-2, both with basis “Reporting”. Its quarterly audits, per Table 4, rate determinations High, Medium or Low by consistency with Original Medicare coverage criteria.

The Data Reporting Guide says CMS expects to begin scoring WISeR-2 “on a pay-for-performance basis later in Performance Year 1”, while saying CMS “will conduct quarterly audits” in early performance periods. CMS’s Aug. 13, 2026 specification lists the measure as “PP1: 1/1/2026 – 3/31/2026 – Pay for reporting” and says its WISeR-2 scoring information “applies to WISeR-2 scoring under pay-for-performance” and is “effective for PP4 and later performance periods” (PP4 began Oct. 1, 2026, per the Participant Guide). No source this edition read states how WISeR-2 was scored in PP2 or PP3.

Who reads a non-affirmation

The Payment Methodology lists “Human review required”: every non-affirmation must be reviewed by an appropriately licensed WISeR clinician or clinical reviewer “to confirm the request does not meet Medicare coverage criteria.” KFF Health News, in a June 23, 2026 article by Darius Tahir, writes that “CMS vendors say humans make the final decisions on approvals,” while doctors and their staffs “believe artificial intelligence is playing a large role in the process and that denials are sometimes the result of AI hallucinations that garble or make up information.” KFF reports that the chief executive of one participating company said he hasn’t heard about any AI hallucinations.

What we read in the file

On our reading, as of CMS’s March 16, 2026 Data Reporting Guide, WISeR-2’s 16 PP1 points could be earned in full by complete, timely submission of the data CMS requested in its quarterly audit, not by the audit’s High, Medium or Low rating, while the Guide kept the audits, those ratings and possible corrective action in the design. The Guide says failing to provide requested documentation “will negatively impact the WISeR-2 score and may also trigger remedial actions, up to and including termination from the model”, and the Payment Methodology says accuracy results “may result in payment reductions for determinations that are inaccurate”. No source read, through Oct. 13, 2026, shows a WISeR-2 score, quality multiplier or payment reduction for any participant. In our view the question travels past Medicare, to any score built on records its subject supplied: what did it read?

Our lens, not CMS’s: we map the record, not any person or company, to Digital Derangement Syndrome™ (DDS™). On our reading, the record is consistent with Decision Exclusion (a decision made without the entity ever entering consideration), with Authority Misclassification contributing (a claim of standing never matched to its true standing).

Where the argument stops

This page does not assess any determination, or say that any audit occurred or that any participant earned or lost points. The sources this edition read, as of Oct. 13, 2026, do not report an audit or its results. They show no WISeR vendor’s quality score, audit rating, quality multiplier or payment amount, and they do not establish that artificial intelligence made any specific WISeR denial. A search of the records read, including CMS’s 443-page FOIA production (much of it searchable only as machine-read text), found no WISeR denial letter sent to a provider or patient. On our reading, neither 2025 paper says whether the final design responded.

Not read: paywalled STAT News (Sept. 15, 2026) and Seattle Times (March 18, 2026) coverage; hearing video and three testimony downloads; Federal Register notice; Request for Applications; Office Hour video; full EFF Deeplinks page; Data Reporting Guide versions 1.0 and 2.0; any participant-facing notice CMS has not posted publicly.

The readings marked ours above, including the DDS™ mapping and the opinion that the question travels past Medicare, are editorial, not any source’s finding.