MEAT, TAMPER, PATIO – and the Regulatory Reality of Risk Adjustment

Risk adjustment has entered a new era. We are no longer operating in a documentation optimization environment; we are operating in an enforcement and recalibration environment.

For years, clinical documentation integrity (CDI) programs focused heavily on a strategy encompassing condition capture, specificity, and query. I have led those initiatives, and they remain important. But with the Centers for Medicare & Medicaid Services (CMS) implementing CMS-HCC Version 28 and finalizing extrapolation authority under Risk Adjustment Data Validation (RADV), unsupported diagnoses now carry materially greater financial and compliance exposure.

Documentation integrity is no longer just about coding accuracy. In my view, it now intersects directly with enterprise governance and compliance risk.

In conversations with physician advisors and CDI teams across the country, I frequently hear reassurance framed around familiar acronyms: “we met MEAT (Monitored, Evaluated, Assessed/Addressed, and Treated) criteria.” “The note satisfies TAMPER (Treatment, Assessment, Monitoring, Plan, Evaluation, and Response) criteria.”

These frameworks are helpful. They create structure, reinforce documentation discipline, and promote consistency in clinical communication.

In many organizations, PATIO became shorthand for the point of presentation: the timestamp when the patient physically arrives at the hospital and clinical evaluation begins, not when the inpatient admission order is written. This difference has become more important as scrutiny of admission status and the timing of medical necessity has increased under the CMS Two-Midnight Rule. CMS regulations specify that an inpatient stay for Medicare payment starts with a valid, authenticated inpatient order. At the same time, the admitting practitioner’s expectation that the patient will need hospital care lasting at least two midnights must be reasonable and based on the clinical information available at the time of the admission decision. The order establishes inpatient status for billing; the clinical narrative begins at arrival. PATIO emphasizes that these are related but separate moments in the compliance timeline.

We need to remind teams of an important point. These are educational constructs, not regulatory standards. That distinction is not subtle; it is foundational.

MEAT, TAMPER, and PATIO have become common documentation prompts within CDI education and broader industry training initiatives. They are frequently discussed in professional association forums and educational programming as tools to improve clarity and consistency in provider documentation. They serve as a structure guide and create shared language between clinicians and CDI professionals.

However, none of these constructs are embedded in a federal statute. They are not codified in the ICD-10-CM Official Guidelines for Coding and Reporting. They are not referenced as validation criteria in CMS risk adjustment rulemaking. They are not audit standards within the RADV methodology.

CMS does not evaluate documentation based on the completion of acronyms. RADV audits assess whether diagnoses submitted for risk adjustment are supported by the medical record documentation.

Regulators evaluate whether a diagnosis is clinically supported, encounter-relevant, and reportable under governing authority.

That is a vastly different standard.

I also believe that it is important to acknowledge something that warrants clearer discussion with physician advisors: MEAT does not mean the same thing in every context.

On the professional coding side, particularly in evaluation and management (E&M) coding, documentation reflecting monitoring, evaluation, assessment, and treatment supports medical decision-making and acuity. It helps determine the appropriate E&M level in accordance with established coding guidelines. In that setting, those elements reflect provider work and complexity.

But risk adjustment operates differently.

E&M coding evaluates the provider’s work and the complexity of medical decision-making.

Risk adjustment evaluates whether a diagnosis may be reported for payment adjustment under federal regulations and program-specific submission requirements.

These are distinct standards. I see confusion arise when the two are blended without clarification.

When MEAT is applied in risk-adjustment conversations, some assume that if the condition appears in the assessment with basic management language, it is automatically defensible for risk-adjustment submission. That assumption can introduce compliance risk.

Under CMS-HCC Version 28, specificity thresholds have shifted, and mapping has narrowed. Certain diagnoses that historically translated into risk-score weight may no longer do so, while others require greater precision to remain reportable. If our education focuses solely on satisfying a documentation model without incorporating Version 28 implications, we risk creating documentation that appears structured, but lacks regulatory alignment.

The enforcement environment reinforces this concern.

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) continues to identify Medicare Advantage (MA) risk adjustment as a focus of oversight. The U.S. Department of Justice (DOJ) evaluates submissions under statutory authority, including the False Claims Act (FCA), rather than documentation frameworks. RADV audits assess whether reported diagnoses are supported in the medical record and properly submitted. With the extrapolation authority finalized, unsupported findings identified through the audit may be applied more broadly within applicable contracts.

When this is shared with teams, it should be emphasized that we are no longer discussing isolated claim adjustments. We are discussing enterprise exposure.

Consider a note that reads: “chronic kidney disease stage 3; stable; continue medications; labs reviewed.”

From a structural standpoint, this may appear sufficient. There is an assessment. There is treatment. Monitoring is implied.

But regulatory scrutiny asks different questions:

• Is the stage supported by current laboratory values?
• Was medication dosing reviewed, considering renal function?
• Did CKD influence medical decision-making during this encounter?
• Is the documentation encounter-specific, or does it reflect copied-forward language without active evaluation?

If the documentation merely confirms the existence of a chronic condition without demonstrating encounter-based evaluation, it may not withstand RADV validation, even if it satisfies a documentation model.

I share this tenet directly in education sessions: structure alone does not equal audit defensibility.

This is where regulatory literacy becomes essential.

In my experience, the most effective documentation programs do not abandon MEAT, TAMPER, or PATIO. They contextualize them. They intentionally layer:

• ICD-10-CM Official Guidelines;
• CMS risk-adjustment regulations;
• RADV validation principles;
• Clinical validity standards; and
• Version 28 mapping implications.

When teaching providers, explicitly outline the regulatory hierarchy. Federal statutes and CMS regulations govern risk adjustment. ICD-10-CM guidelines govern code assignment. RADV defines validation standards. HHS OIG oversight priorities signal enforcement focus. Documentation frameworks sit beneath this hierarchy.

When guidance and regulation diverge, regulation prevails.

Once teams understand hierarchy, documentation conversations shift. The focus moves from “did we meet the structure?” to “would this withstand regulatory review?”

That shift matters.

This does not mean overwhelming providers with regulatory language. It means being transparent about why documentation expectations exist. It means explaining that unsupported diagnoses may be subject to recoupment and extrapolation. It means clarifying that specificity matters under Version 28. It means reinforcing that templated language without encounter engagement may expose your organization to compliance risks.

A high-functioning physician advisor program is uniquely positioned to lead this evolution. They understand clinical reasoning. They understand acuity. They understand medical decision-making. Increasingly, they must also understand risk-adjustment regulations.

Their role, as I see it, is not to police documentation; it is to translate regulatory expectations into clinically meaningful standards.

In the current enforcement climate, documentation must simultaneously demonstrate clinical truth, coding alignment, and regulatory defensibility.

Documentation models support the first, and partially support the second. Regulatory literacy strengthens the third.

I will continue to teach MEAT, TAMPER, and PATIO. They remain valuable structure prompts. But I will be explicit in how I frame them. They are educational tools. They are structured guidance. They are not regulatory safe harbors.

Risk adjustment has matured into a compliance and governance discipline. Documentation integrity now sits squarely within enterprise risk management. We must teach the frameworks. We must embed the regulations. And we must ensure that documentation education reflects both clinical reality and governing authority.

Anything less leaves institutions exposed.

EDITOR’S NOTE: The author of this article used AI-assisted tools in its composition, but all content, analysis, and conclusions were based on the author’s professional judgment and expertise. The article was then edited by a human being.