Compliance & Legal Risk

In the last 24 hours, compliance and legal risk for VBC stakeholders remain acutely focused on evolving CMS reporting requirements tied to drug wastage and specific billing protocols. CMS continues to stress the mandatory use of the JW modifier for OPPS hospitals when billing for discarded drug amounts, a technical nuance impacting population health reimbursement and ACO audit exposure if not followed precisely [[RAC Monitor: JW modifier requirements]](https://racmonitor.medlearn.com/general-question-for-the-week-of-april-27-2026/). Additionally, clinical coding teams must be vigilant in using precise HCPCS codes for laboratory reporting; labs are now required to use specific PLA codes when tests qualify, rather than defaulting to similar Category I codes, tightening compliance standards for payer models and population health contracts [[RAC Monitor: PLA coding for labs]](https://racmonitor.medlearn.com/laboratory-question-for-the-week-of-april-27-2026/). These updates elevate the importance of robust coding audits and real-time response strategies for ACOs and provider organizations to avoid financial penalties under the current CMS oversight framework.