Inside an RCC Analysis: How and Why Experts Assess Past Medical Billing

August 26, 2026

by Amber Allison, Ph.D., C.L.C.P., Director of Research and Training

In personal injury litigation, medical expenses often represent a significant portion of the damages claimed. Attorneys are frequently presented with extensive medical billing records that may include hospital charges, physician fees, surgery center charges, diagnostic testing, therapy services, durable medical equipment, and other treatment-related expenses. While these records document what a provider billed, they do not necessarily answer a separate and important question: were the charges usual, customary, and reasonable (UCR) for the services provided in that geographic area?

At Vocational Diagnostics, Inc. (VDI), our Reasonableness of Cost of Care (RCC) service is designed to help answer that question. In addition to our earning capacity evaluations, assessment of future care needs, and life care planning services, RCC analyses provide an objective review of past medical billing charges that are claimed as damages in litigation.

What Is a Reasonableness of Cost of Care Review?

A Reasonableness of Cost of Care review evaluates billed medical charges by comparing them to geographically specific benchmark data for the same or similar services. The analysis begins with a careful review of the medical billing records and the services rendered after the date of incident. Each service is evaluated according to the applicable billing codes, such as Current Procedural Terminology (CPT) codes, Healthcare Common Procedure Coding System (HCPCS) codes, Diagnostic Related Groups (DRG), or Medicare-Severity Diagnostic Related Groups (MS-DRG), depending on the type of service and billing record involved.

Once the appropriate codes are identified, the billed charges are compared to recognized healthcare charge databases. VDI relies on resources such as FAIR Health and Context4 Healthcare, which provide geographically specific charge information and are commonly used by professionals involved in life care planning, medical billing review, and damages analysis.

Why Geography Matters in Medical Billing Analysis

Medical charges can vary widely depending on where care is provided. A charge that may fall within the expected range in one market may be unusually high in another. For that reason, an RCC analysis does not simply compare a bill to a national average. Instead, it considers the geographic location where the service was rendered and compares the billed charge to charges for similar services in the same or comparable area.

FAIR Health organizes healthcare charge data by geographic regions known as geozips, and Context4 Healthcare relies on actual zipcodes. This allows charges to be evaluated in a way that reflects local healthcare markets rather than relying on broad, generalized pricing assumptions. This geographic specificity is important in litigation because it provides a more defensible basis for determining whether a billed charge is consistent with what providers in that area typically charge for the same or similar service.

Understanding Usual, Customary, and Reasonable Charges

The term usual, customary, and reasonable, often abbreviated as UCR, refers to whether a medical charge is consistent with what is typically charged for the same or similar service in a particular geographic area. In practical terms, this means the analysis considers whether the provider’s billed charge falls within an expected range when compared to charges submitted by other providers for comparable services.

This distinction is important because a billed charge is not the same as the amount ultimately paid by an insurer, third-party payer, or patient. In healthcare finance, a provider’s charge represents the dollar amount set for a service before discounts or negotiated adjustments are applied. The price or amount paid may differ substantially from the original billed charge. RCC analysis focuses on the reasonableness of the billed charge itself, independent of collateral source payments or negotiated reimbursement arrangements.

How Percentile Benchmarks Are Used

Healthcare charge databases commonly present benchmark data by percentile. For example, if a charge falls at the 50th percentile, that means half of the reported charges for that service fall at or below that amount and half fall above it. A charge at the 75th percentile is higher than approximately 75 percent of comparable charges, while a charge at the 90th percentile is higher than approximately 90 percent of comparable charges.

In many RCC analyses, charges above the 90th percentile are identified as exceeding the usual, customary, and reasonable range for the service and geographic area reviewed. This approach is conservative because it does not classify a charge as unreasonable merely because it is above average. Rather, it identifies charges that exceed what the vast majority of providers in the relevant market charge for the same or similar service.

Why RCC Reviews Are Useful for Attorneys

An RCC analysis can assist counsel in understanding whether claimed medical charges are supported by objective market-based data. It may also help frame discovery questions, support settlement evaluation, inform mediation strategy, or provide expert analysis for use in litigation. Importantly, the review does not determine whether the treatment was medically necessary, causally related, or appropriate from a clinical standpoint unless that issue is separately addressed by a qualified medical expert. Instead, RCC focuses specifically on whether the amount charged for the service was reasonable in relation to comparable charges.

VDI’s Approach to RCC Analysis

VDI’s RCC service combines detailed billing review with recognized healthcare charge data. Our experts analyze the treatment-related billing records, identify the applicable codes, compare the billed amounts to geographically specific benchmark data, and explain the findings in a clear, litigation-focused format. The goal is to provide attorneys with a transparent, objective assessment of whether the billed charges fall within or exceed the UCR range.

Because medical billing terminology can be complex, our reports are written to be understandable to attorneys, claims professionals, and other litigation stakeholders. We aim to explain not only the numerical findings, but also the methodology behind the analysis so that counsel can evaluate the significance of the findings within the broader context of the case.

Learn More About VDI’s RCC Services

VDI offers Reasonableness of Cost of Care reviews as part of our broader suite of forensic vocational, life care planning, and damages-related services. If your case involves significant past medical billing or questions regarding the reasonableness of claimed medical charges, an RCC analysis may help clarify the issues and support a more informed evaluation of damages.