Medicare Advantage · MMR Recovery Analytics

You're Likely Being
Underpaid for Your
ESRD Members.

A subset of your ESRD members are being reimbursed at the wrong CMS rate — up to $72,000 per member per year. We identify them, coordinate the missing CMS 2728 filings with their dialysis centers, and pursue the recovery through CMS.

Data Ingestion
Claims + membership data
AI Analysis Engine
Proprietary detection model
ESRD Flag
Status gap detection
Rate Check
Differential calculation
Transplant
Transition analysis
Recovery Report
Quantified underpayments
2728 Submission
Dialysis center outreach

Request a Free Revenue Recovery Audit

Share your details and we'll schedule a brief call to understand your plan's ESRD enrollment profile. We'll tell you whether there's an opportunity before you commit to anything.

contact@clearcapitation.com
HIPAA-Compliant · BAA Available
AES-256 Encrypted Transfer
Free Audit · No Commitment

Founder responds personally within 1 business day.

Audit Request Received

We'll review your information and reach out within one business day to schedule your free revenue recovery audit.

ESRD Underpayment Is a Systematic Revenue Leak — and Most Plans Never See It.

ESRD members trigger a dramatically higher CMS capitation rate — but only when their dialysis facility submits a CMS 2728 form to establish status. For many members, that submission never happens or never reaches CMS. The result: your plan is paid the standard rate instead of the ESRD rate, month after month, with nothing in your reporting to signal the gap.

See how the gap compounds →
up to
$72,000

per member per year — for each gap category we screen:

  • Unestablished ESRD status
  • Incorrect effective dates
  • Transplant & graft transitions
  • Rate misapplication
3–8x
higher capitation rate for ESRD members vs. standard — making underpayment disproportionately costly
~$72,000
annual capitation differential when an ESRD member is scored under the standard CMS model instead of the ESRD model
12–36+ mo
how long these gaps typically persist before anyone catches them
84 mo
the CMS retroactive recovery window we work within

Every Month You Wait, Recovery Gets Harder.

From the moment status is missed

The member is reimbursed at the wrong rate, every month.

The gap compounds

Each uncaptured month adds to the recoverable total, up to the CMS window.

Recovery stays possible — but not forever

The longer a gap goes unaddressed, the more difficult and time-sensitive the recovery becomes.

Acting early

Is the single biggest driver of how much you actually recover.

CMS allows retroactive recovery going back several years — but the opportunity erodes the longer a gap sits unaddressed. The plans that recover the most are the ones that move first.

A Fully Managed Path From Data to
Recovered Revenue.

Our process is fully managed and proprietary. You provide your data; we handle everything else — identifying the members, establishing what's owed, managing the correction end to end with the relevant parties, and tracking each dollar through to confirmed CMS recovery. Minimal internal lift required.

01

Discovery

We ingest your data and surface the members who are being underpaid — using methods that go well beyond a standard reporting review.

Output Candidate list of underpaid members with quantified differential
02

Validation & Quantification

We confirm each opportunity, establish the correct figures, and quantify what's recoverable within the CMS window.

Output Confirmed member list with quantified recovery opportunity
03

Dialysis Center Outreach & 2728 Submission

We contact each member's dialysis center directly, confirm whether a CMS 2728 was ever submitted, and drive submission of any missing or corrected forms. This is the operational step that converts the gap into paid revenue — and the part most plans can't execute internally.

Output Verified 2728 submissions filed with CMS for every identified member
04

Confirmed Submission

We close the loop with each dialysis center to confirm the 2728 has been filed. Once a submission is confirmed, the recovery is locked in — CMS handles payment from there.

Output Confirmed 2728 submissions across the identified cohort

Performance-Based.
You Only Pay When We Recover.

Contingency Model
12%
of recoverable revenue

You keep 88% of money you didn't know you were owed.

Recoverable amounts vary by plan size and how long each gap has persisted — frequently reaching six or seven figures. We'll size yours during the free audit.

  • No upfront costs or retainers
  • Billed on confirmed 2728 submission (before CMS payment reaches you)
  • Free initial audit — zero commitment
Request Your Free Audit →

We focus on anomalies and patterns that MA plans systematically miss.

Clear Capitation was founded by Hari Jayaraman. He spent five years at ZS advising top pharma and digital health companies on turning EHR and claims data into working clinical and commercial systems, after earlier stops in precision medicine strategy at DeciBio and financial reporting at BlackRock.

The pattern across that work is anomaly detection in complex data. ESRD capitation underpayment fits it exactly — unusual signals hiding in claims and membership data that internal reporting isn't built to surface. Our tools were built with insights from actuaries working with leading insurers.

Clear Capitation is early. We're taking on a small number of Medicare Advantage plans as design partners on contingency, with direct founder access and terms that reward the plans willing to move first.

→ LinkedIn: linkedin.com/in/hari-jayaraman-13e7
→ Email: contact@clearcapitation.com

Frequently Asked Questions

How do you find underpaid ESRD members that our internal team hasn't?

Most internal reviews rely on the MMR at face value. Our analytics cross-reference claims data — dialysis procedures, session frequency, ESA utilization — against the ESRD flags on your MMR. Where claims show dialysis activity and the MMR shows no ESRD status, that's a recoverable gap. This type of cross-source detection is purpose-built and not something standard reporting surfaces.

What data do you need from us to get started?

We need your claims data and Monthly Membership Report (MMR) files. We handle all ingestion and parsing. The initial data pull is typically the only internal lift required — everything after that is fully managed on our side.

How far back can CMS recoveries go?

CMS allows retroactive corrections up to 84 months (7 years) back. This applies regardless of whether the member is still enrolled — recovery attaches to the months they were in ESRD status, not their current enrollment. The earlier you act, the more months fall within the window.

What does "contingency-based" mean? Are there any upfront costs?

None. We charge 12% of recoverable revenue, billed once dialysis centers confirm 2728 submission, before CMS payment reaches your account. If we don't successfully drive submission, you pay nothing. There are no retainers, setup fees, or minimum commitments. The free audit itself carries zero obligation.

How do you handle PHI and sensitive data?

All data is transferred via AES-256 encryption. We operate under HIPAA-compliant protocols and offer a Business Associate Agreement (BAA) before any data changes hands. Access is restricted to authorized personnel only, and we maintain SOC 2-aligned controls for data handling and storage.

How long does the process take from start to recovery?

The initial audit and discovery phase completes within the first few weeks. Once a 2728 is submitted, CMS handles payment on its own timeline. We stay engaged through confirmation and see the process through to close.