CMS-2026-1090-DRAFT-0002

Status: Original and derived artifacts are available for this document.

Download: pdf

PUBLIC SUBMISSION

As of: 4/7/26, 11:54 AM
Received: April 05, 2026
Status: Draft
Category: Health Care Industry - PI015
Tracking No. mnl-xylf-t66a
Comments Due: May 18, 2026
Submission Type: Web

Docket: CMS-2026-1090
Good Cause Processes (CMS-10544)
Comment On: CMS-2026-1090-0001
Good Cause Processes (CMS-10544)
Document: CMS-2026-1090-DRAFT-0002
Comment on CMS-2026-1090-0001

Submitter Information
Name: Nakul Karkare
Address:
Stony Brook, NY, 11790
Email: [email protected]
Phone: 6319812663

General Comment
When a beneficiary is reinstated after involuntary disenrollment, the claims spanning
that coverage gap become the evidentiary record. If those claims carry ambiguous,
physician-selected procedure codes, CMS cannot reliably determine what services
actually occurred — or whether the non-payment was genuinely unforeseen.
I have developed a deterministic procedure coding system. Codes are generated
automatically from data already present in the claim. No physician selects them. No
judgment is exercised. No two providers can code the same service differently. Every
element of every code traces directly to its source — nothing is opaque.
For Good Cause reinstatement review, this means CMS gains a precise, auditable
picture of the clinical record during the disputed period. Fraud disguised as
administrative error becomes detectable. Legitimate gaps become provable. The
burden on beneficiaries — currently estimated at 36,490 annual hours — shrinks when
documentation disputes disappear.
The system is complete, tested, and available at no cost.
Nakul Karkare MD https://www.newyorkhipknee.com/ https://www.cortho.org