What is unbundling and why is it noncompliant?

• A. Submitting separate codes for components that should be billed as a single comprehensive code; results in higher reimbursement and constitutes improper billing.
• B. Submitting a single code for all services, even when separate codes are required.
• C. Billing for services not provided due to fraud.
• D. Averaging charges across patient populations to set pricing.

Answer: (A)

Unbundling is submitting separate codes for components that CMS has bundled into a single comprehensive code. This allows billing each piece individually, which often boosts reimbursement beyond what the bundled code would pay for the same services. Because the services are intended to be billed together under one code, unbundling violates coding rules and constitutes improper billing. If done knowingly to obtain higher payments, it can trigger enforcement actions, repayment obligations, and civil penalties, since it amounts to false or fraudulent billing under programs like Medicare.

So, this option best fits unbundling and noncompliance: it describes separating components that should be billed as one code, leading to higher, improper payment. The other scenarios describe different issues—billing a single code for all services when separate codes are required would be undercoding or incorrect coding, billing for services not provided is fraud, and averaging charges to set pricing is a pricing practice not about coding—so they don’t capture the concept of unbundling.