A fast-growing cardiology group, already beating its peers — with capturable revenue sitting in plain sight.
An anonymized 2026 Practice Assessment of a real 3-provider cardiology group. Every figure traces to CMS Medicare claims (CY2024 — public data runs ~18 months behind real-time, and we label that vintage on every finding) plus public web scans. Findings that name unavoidable loss are marked not recoverable; opportunities are marked as bounded, never promised. Practice identity withheld.
About this engagement
- Practice type
- Independent cardiology group
- Size
- 3 providers
- Engagement
- Practice Assessment, 2026
- Dataset
- CMS Medicare claims (CY2024) + public web scans
- Delivery
- Report + dashboard activation
Findings — by domain
Each finding is labeled by what it actually is: a diagnosis names a loss you cannot recover; an offset is revenue you can capture; context is a signal with no dollar attached.
Top-of-cohort revenue, still growing
Per-provider Medicare revenue of $951K sits at the top of the state cardiology distribution (peer median ~$218K), and grew ~8%/yr while peer practices were roughly flat. Source: CMS Medicare Physician & Other Practitioners PUF, CY2024.
Medicare rate erosion on core procedures
~$17.5K/yr at-prior-rate differential across declining cardiology codes (e.g. implantable cardiac monitor insertion, 33285). A counterfactual — what current volume would have earned at prior Medicare rates. It names the erosion every practice feels; it is not recoverable, because CMS sets the rate.
Commercial-vs-Medicare rate gap
~$114K/yr differential between commercial and Medicare rates on benchmarked codes, derived from public Transparency-in-Coverage negotiated-rate files. Descriptive context for contract strategy.
Chronic-care programs unbilled
Remote Patient Monitoring (99457/99454), Chronic Care Management (99490), and Transitional Care Management (99495/99496) are all at 0% adoption vs state peers (RPM ~11%, CCM ~4.3%) — across 1,528 Medicare beneficiaries, many with qualifying chronic conditions. CMS-reimbursed programs left entirely unbilled.
Eligible telehealth volume unbilled
Zero telehealth visits against 5,054 established-patient encounters in telehealth-eligible codes — a standing billable channel unused. Corroborated independently: the practice's public site lists no virtual-visit option.
In-market service-line headroom
Four cardiology codes that in-market peers bill this practice does not (including extended rhythm monitoring 93244/93242), plus ~27,430 services in adjacent-metro codes not currently offered. Quantified from CMS geographic utilization, not speculation.
Third-party trackers on patient-facing pages
A behavioral privacy scan (hosted Blacklight) observed four third-party trackers — Google Analytics 4 and Google Tag Manager — firing page-view events from patient-facing pages, with data flowing to Google. No advertising pixels, session recorders, keystroke capture, or canvas fingerprinting were observed. The HHS OCR December 2022 tracking-technologies bulletin places analytics on health-related pages within HIPAA scope even without PHI in the payload. We report what we observed on the scan date — not a legal conclusion or a penalty prediction. Regulators and courts have pursued this conduct class in health-care settings (see the enforcement precedent below). Source: HHS OCR tracking-technologies guidance.
Online front-door gaps
No online scheduling, no patient portal or FAQ, and site content roughly two years stale — friction on new-patient capture for a practice that is otherwise growing. Source: automated usability scan (Nielsen heuristics).
Accessibility came back clean
Zero WCAG 2.2 AA violations from the automated scan (axe-core): form labels and skip-navigation present. We flag what we find — here there was nothing to flag. The one low-effort hardening step is publishing an accessibility statement.
Regulatory context
For scale on the web-privacy finding: regulators and courts have penalized third-party tracking in health-care settings, and HIPAA civil penalties are set by statute (45 CFR 160.404). These describe the enforcement landscape and regulatory structure — not a determination, prediction, or exposure figure for this practice.
Enforcement precedent
- Novant Health — $6.6M class settlement (2024): a Meta tracking pixel on its websites and patient portal disclosed information on ~1.3M patients to Meta.
- FTC v. GoodRx — $1.5M civil penalty (2023): sharing users’ health data with Meta and Google through tracking technologies.
- FTC v. BetterHelp — $7.8M (2023): disclosing consumers’ health information to advertisers.
Sources: Novant Health consolidated Meta Pixel class-action settlement (2024); FTC enforcement actions (2023). These are larger organizations and different tracking mechanisms — cited as the enforcement landscape, not analogues for this practice.
Statutory penalty tiers
| Culpability tier | Per violation | Annual cap |
|---|---|---|
| Lack of knowledge | $145 – $36,506 | $36,506 |
| Reasonable cause | $1,461 – $73,011 | $146,053 |
| Willful neglect, corrected | $14,602 – $73,011 | $365,052 |
| Willful neglect, not corrected | $73,011 – $2,190,294 | $2,190,294 |
Source: 45 CFR 160.404; HHS 2026 annual civil monetary penalty inflation adjustment, effective January 28, 2026. Annual cap applies per identical-provision violation.
What the levers are
The diagnosis — Medicare rate erosion and the commercial-rate gap — is the loss this practice feels but cannot bill its way out of. The offsets are where the felt loss gets answered: standing up the chronic-care programs (RPM, CCM, TCM) the practice already qualifies for, opening the unused telehealth channel, and the in-market service lines its peers already bill.
On the web side, the third-party-tracking exposure is a remediation item with a named regulatory basis; the accessibility scan, by contrast, came back clean. Ralt Rounds then monitors reimbursement drift, re-benchmarks on every federal data release, and re-runs the compliance scanners on a schedule.
What would your numbers look like?
Every assessment is specialty-benchmarked. Cardiology sees different levers than primary care, which sees different levers than orthopedics. Inquire to scope a starting line for your practice.
Inquire to scope