caliber
Billing Governance Standard
BGS v1.0 — April 2026
The first published methodology for independent, pre-payment billing verification of high-cost claims during the TPA hold window.
01 — What It Is
Independent pre-payment verification of high-cost healthcare claims during the TPA hold window. Every self-funded employer holds claims above a defined threshold for 14-60 days before releasing payment. During that window, nobody independently verifies that what was billed matches what was delivered. The TPA processes and releases. Caliber fills that window with structured, external verification against coding guidelines, provider contracts, clinical documentation, and delivery evidence.
02 — The Seven Checks
CodeCheckDescription
CODEVALCoding AccuracyCPT/HCPCS consistency with diagnosis, procedure, and level of service. Catches upcoding, unbundling, incorrect modifiers.
DUPCHECKDuplicate DetectionPrior billing for same member, date, and provider. Catches duplicate submissions and overlapping facility/professional billing.
RATEVALRate VerificationBilled amount vs. correct contracted rate for the network tier accessed. Catches balance billing, wrong fee schedule, out-of-contract charges.
DURVALDuration VerificationBilled length of stay vs. clinical documentation for inpatient and residential claims. Catches LOS discrepancies and post-discharge billing.
CREDVALCredential VerificationBilling provider credentialed at the level billed. Catches physician-rate billing for NP/PA-delivered services.
SVCVALService VerificationTriggered when other checks raise flags. Requests clinical documentation from provider. Catches phantom billing and incomplete-service charges.
BUNDLEVALBundle ComplianceSeparately billed services that should be bundled per CMS/industry guidelines. Catches unbundling and fragmented billing.
03 — Review Thresholds
TierClaim AmountReview Scope
Tier 1$25,000+Full verification: coding, billing, documentation, contract compliance.
Tier 2$10,000 - $24,999Coding and billing verification. Documentation review if flagged.
Tier 3Below $10,000Automated screening only. Manual review if algorithmically flagged.
Default full-verification threshold: $25,000. Captures approximately 70-80% of high-cost claims spend in 5-10% of total claim volume. Configurable per employer.
04 — Determinations
OutcomeMeaning
VerifiedClaim is accurate. Pay as submitted.
AdjustClaim contains correctable inaccuracies. Recommended adjustment documented.
HoldAdditional documentation required from provider before verification can complete.
EscalateMaterial discrepancies requiring employer/TPA decision. Caliber documents findings and recommends action. The employer decides. Advisory-only.
Caliber never denies a claim. We verify, adjust, or escalate. The employer and TPA retain full authority over the payment decision. Same structural principle across the platform: advisory-only.
05 — Turnaround
TPA Hold WindowTier 1Tier 2
Standard (14-60 days)10 business days7 business days
Short hold (14-21 days)5 business days3 business days
Caliber guarantees turnaround within the hold window. If turnaround is not met, the claim passes through unreviewed. The employer never pays late because of Caliber.
06 — The Deliverable
Billing Governance Certificate
Quarterly. Produced at the end of each 90-day verification cycle.
Sealed. Immutable after issuance. No post-seal alteration or selective exclusion.
Versioned. Each certificate references the BGS version and configuration fingerprint used.
Documents: verification rate, adjustment rate, escalation rate, total billing discrepancy, prevented overpayment, discrepancy distribution by type, provider accuracy scores, and trend analysis. Serves as evidence for stop-loss renewal, ERISA fiduciary documentation, and board reporting.
07 — Reviewer Qualifications
All claims reviewed by external billing governance specialists. Minimum credentials: CPC (Certified Professional Coder), CCS (Certified Coding Specialist), or RHIA (Registered Health Information Administrator). Minimum 3 years of claims review experience. Reviewers must be external to the employer, the TPA, and the provider. Independence is structural, not optional.