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Nishi Compare · measured, not asserted
Medical Billing and Patient Advocacy
Nishi vs the field — every Nishi cell is measured against real organ source at emit time; each gap names the watch contract that will close it.
Nishi vs Goodbill and Turquoise Health and Waystar and Tebra
Layer 1 · Executive
Where we are. Measured 2026-08-19. The patient-side loop is live and gate-proven: audit (duplicates, NCCI, MUE, fair price), dispute and appeal letters with computed deadlines, NSA routing, charity care, civic escalation with an accountability ledger, payoff planning and a zero-JS portal -- with the privacy and fail-safe exceeds nobody else ships. The six absent rows are the provider-side and payer-wire capabilities the incumbents are built on: price-file ingest, eligibility, EDI, denial prediction, prior auth and autocoding.
Where we need to go. Keep the patient-first moat and add the payer wire: price truth from the hospitals' own files, 270 and 271 and 837 and 835 on banked samples, then prevention (denial prediction, prior auth) and the coding frontier -- every figure in cents, every rule a data pack, nothing auto-sent.
The unit. 1 u = one measured session-leg. Calibration from landed rungs: the mangagen panel compositor went from existing substrate to shipped and live-verified in ONE leg (2026-08-13); the citations rung went from 3 to 55 domains in one leg across seven seats (2026-08-18); a greenfield engine with a bite-proven gate has measured 2 to 4 legs. Estimates recalibrate as rungs land and PR7 actuals write back.
Cost to price truth: 1.5 u. Through M0: one ingest organ that feeds the fair-price pack the audit already reads.
Cost to the payer wire: 6 u. Through M1. Eligibility and EDI are real format work on banked samples and are the dependency for prevention.
Cost to the frontier: 12 u. Everything below. Autocoding rides the sovereign LLM seat and abstains below threshold.
20 of 28 capabilities measured|4 of them measured exceeds|8 open|coverage 714/1000|adoption 16 full / 4 partial
Layer 2 · Roadmap
Do this next — computed by the ranker, never chosen by a seat
Order from nx_compare_rank (nx_dr_ocm: (deficit + cost-of-delay + option + enables) x sponsor x self-sufficiency x momentum / cost). FINISH rows are rungs whose symbol is present but whose organ is short of full adoption: the cheapest closures on this board, listed before any new work. Stamp: # asof=1787883502 domain=medbilling target_version=0.1 rungs=6 done=0 open=6 finish=0 ranker=nx_dr_ocm
| # | Stage | Rung | Priority | Derivation |
|---|---|---|---|---|
| #1 | 0.1 | Hospital price-transparency ingest (R0) mbp_ingest | 933 | v=14 m=1 c=15 |
| #2 | later | Eligibility and benefits 270 and 271 (R1) mbel_check | 600 | v=12 m=1 c=20 |
| #3 | later | Prior-authorization drafting (R4) mbpa_draft | 466 | v=7 m=1 c=15 |
| #4 | later | EDI 837 and 835 (R2) mbe_parse | 400 | v=10 m=1 c=25 |
| #5 | later | Autocoding from clinical text (R5) mbac_suggest | 360 | v=9 m=1 c=25 |
| #6 | later | Denial prediction before submission (R3) mbd_score | 350 | v=7 m=1 c=20 |
Critical path — contract, done-rule, executor, cost
| Rung | Closes with | Definition of done (pre-declared) | Executor | Est. |
|---|---|---|---|---|
| Hospital price-transparency ingest (R0) | mbp_ingest | CMS machine-readable files (JSON and CSV) for a named hospital ingested sovereignly into the fair-price pack; aud_fairprice reads the pack; row count, source URL and content pin printed with every ingest | Organ | 1.5 u |
| Eligibility and benefits 270 and 271 (R1) | mbel_check | An X12 270 built and a 271 parsed against banked samples; coverage, deductible and copay fields extracted; no PHI leaves the machine by construction (the privacy exceed this lane holds) | Organ | 2 u |
| EDI 837 and 835 (R2) after R1 | mbe_parse | 837 claim and 835 remittance parse and emit round-trip on banked samples; the 835 feeds mbr_recon so reconciliation reads the payer's own remittance | Organ | 2.5 u |
| Denial prediction before submission (R3) after R2 | mbd_score | A rule-and-data scorer over claim lines (NCCI, MUE, eligibility, payer rules as packs) predicts denial reasons before submission; precision on the banked EOB set is PRE-DECLARED and printed | Organ | 2 u |
| Prior-authorization drafting (R4) after R1 | mbpa_draft | The payer PA request drafted from claim and codes with deadlines filed into the reminder engine already proven for appeals; a human reviews and sends, never the organ | Organ | 1.5 u |
| Autocoding from clinical text (R5) | mbac_suggest | The sovereign LLM seat suggests CPT and ICD from note text; accuracy against a banked coded set is published; the organ ABSTAINS below a declared confidence rather than guess | Local model | 2.5 u |
Milestones
| Milestone | Rungs | Cumulative |
|---|---|---|
| M0 · Price truth at scale | R0 | 1.5 u |
| M1 · On the payer wire | R1,R2 | 6 u |
| M2 · Prevent, not just dispute | R3,R4 | 9.5 u |
| M3 · Frontier | R5 | 12 u |
Layer 3 · Engineering
How this is scored. Every Nishi mark is measured: the generator reads the real organ source on disk and requires the implementing symbol to exist (no self-grading). A watching tag names the organ and symbol contracted to close a gap — the mark flips itself on the next compare beat when that workstream ships, and the
comparewatch- plane row flips with it. The flip is necessary, not sufficient: it proves the symbol exists, never that the capability is good. The bar is the rung's pre-declared done-rule, proven by its gate — a symbol shipped without the behaviour behind it is a defect, and the flip is exactly what makes that defect visible instead of quiet. Competitor marks record documented capability presence — presence, not depth or scale. Adoption is measured too: every measured row carries where its organ stands on the estate's ladder (source → built → promoted → registered → invoked; libraries by importer reach minus validation importers; gates by the execution surfaces that run them). A row is fully adopted only at the top of its ladder; anything short is tagged partial with the exact remedy, so a build nobody promoted can no longer read as shipped. Census stamps: importers asof 1787849099, gate census asof 1787855507 (unix seconds; -1 = census absent).Capability matrix — measured against source
◉ leads / measured exceed● present◐ partial○ absent · click any capability for its evidence
| Capability | Nishi | Goodbill | Turquoise Health | Waystar | Tebra |
|---|---|---|---|---|---|
Itemized-bill duplicate-charge detectionMeasured:aud_duplicates exists in runtime/nx_fin_audit.nx, verified at emit. Same code plus date billed twice flagged with exact overcharge cents; gate-proven on a real cancer bill Adoption: LIB-WIRED importers=9 nonval=3 — fully adopted (top of its ladder). | ● | ● | ○ | ● | ◐ |
NCCI unbundling editsMeasured:aud_unbundle exists in runtime/nx_fin_audit.nx, verified at emit. Comprehensive-plus-component pair both billed; pairs are data packs not hardcode [cms-ncci] Adoption: LIB-WIRED importers=9 nonval=3 — fully adopted (top of its ladder). | ● | ◐ | ○ | ● | ◐ |
Medically-Unlikely-Edits over-units checkMeasured:aud_mue exists in runtime/nx_fin_audit.nx, verified at emit. Units over MUE max flags the excess-unit share exactly Adoption: LIB-WIRED importers=9 nonval=3 — fully adopted (top of its ladder). | ● | ◐ | ○ | ● | ◐ |
Fair-price check vs Medicare benchmarkMeasured:aud_fairprice exists in runtime/nx_fin_audit.nx, verified at emit. Turquoise price data is the industry reference [turquoise]; our multiplier knob is jurisdiction data Adoption: LIB-WIRED importers=9 nonval=3 — fully adopted (top of its ladder). | ● | ● | ◉ | ◐ | ○ |
Patient dispute and appeal letter generationMeasured:disp_build exists in runtime/nx_fin_dispute.nx, verified at emit. Goodbill negotiates on the patient's behalf [goodbill]; ours renders a cited ready-to-send letter Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ● | ◉ | ○ | ◐ | ◐ |
No-Surprises-Act grounds cited in disputesMeasured:No Surprises Act exists in runtime/nx_fin_dispute.nx, verified at emit. Letter cites NSA plus FDCPA plus NCCI and MUE grounds from the banked corpus Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ● | ● | ◐ | ◐ | ◐ |
Coding rules as swappable data packsMeasured:rp_put exists in runtime/nx_fin_rules.nx, verified at emit. Second jurisdiction pack changes the audit result; proves data-driven not constants Adoption: LIB-GATE-ONLY importers=1 — PARTIAL: imported only by validation organs (gates, tests, benches): wire it into a shipping program. | ● | ○ | ◐ | ● | ◐ |
Scanned-bill OCR ingestMeasured:ocr_classify exists in runtime/nx_ocr_classify.nx, verified at emit. Sovereign glyph classify plus assemble Adoption: LIB-GATE-ONLY importers=1 — PARTIAL: imported only by validation organs (gates, tests, benches): wire it into a shipping program. | ● | ● | ○ | ● | ◐ |
Bill and EOB classify plus field extractionMeasured:dcl_classify exists in runtime/nx_doc_classify.nx, verified at emit. Doc-intelligence lane classifies and digs dates and amounts Adoption: LIB-GATE-ONLY importers=1 — PARTIAL: imported only by validation organs (gates, tests, benches): wire it into a shipping program. | ● | ● | ○ | ● | ◐ |
EOB-vs-bill reconciliationMeasured:mbr_recon exists in runtime/nx_medbill_recon.nx, verified at emit. M2 live: bill and EOB text parse to claim lines; consuming matcher flags not-on-EOB and above-allowed in exact cents Adoption: LIB-WIRED importers=2 nonval=1 — fully adopted (top of its ladder). | ● | ● | ○ | ◐ | ◐ |
Charity-care screening plus 501(r) FAP requestMeasured:mbch_fpl exists in runtime/nx_medbill_charity.nx, verified at emit. Current-year HHS poverty pack grounded against the banked aspe.hhs.gov source; letter invokes the 501(r)(6) collection hold [irs-501r] Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ● | ◐ | ○ | ● | ○ |
Denial appeal letters with computed deadlinesMeasured:mba_letter exists in runtime/nx_medbill_appeal.nx, verified at emit. Reason-specific internal appeal, leap-safe 180-day deadline math, external-review escalation Adoption: LIB-WIRED importers=5 nonval=4 — fully adopted (top of its ladder). | ● | ◐ | ○ | ● | ◐ |
NSA situation classifier and PPDR routingMeasured:nsa_classify exists in runtime/nx_medbill_nsa.nx, verified at emit. Routes emergency-OON and in-network-facility cases to NSA protection and uninsured GFE-overage cases to the 120-day PPDR window; route 4 fabricates no shield [cms-nosurprises] Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ● | ◐ | ○ | ◐ | ○ |
Civic escalation with accountability scorecardMeasured exceed:cv_verdict in runtime/nx_medbill_civic.nx, verified at emit. Opt-in complaint patterns routed DOI CMS AG IRS-13909 CFPB OIG representative plus a case ledger whose MOVING or OVERDUE-UNRESPONSIVE verdict is computed from real dates; no rival ships oversight accountability Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ◉ | ○ | ○ | ○ | ○ |
Deadline tracking into the reminder engineMeasured:cli_deadline exists in runtime/nx_medbill_cli.nx, verified at emit. Appeal PPDR and civic windows file as calendar events; the gated vizsla reminder engine surfaces them at 14 7 1 0-day leads with a sent-once ledger; proven live Adoption: BUILT-UNPROMOTED — PARTIAL: compiled, never promoted to the serving root: /api/promote it. | ● | ◐ | ○ | ● | ◐ |
Medical-debt payoff planningOpen — no implementing organ is measured for this axis yet. Avalanche vs snowball with exact interest; measured 727 dollars saved on the worked case | ○ | ◐ | ○ | ○ | ○ |
Predatory-financing scam shieldMeasured exceed:fe_is_safe in runtime/nx_fin_finance.nx, verified at emit. Advance-fee and unlicensed lenders excluded from ranking by construction; nobody else ships this Adoption: LIB-WIRED importers=4 nonval=2 — fully adopted (top of its ladder). | ◉ | ○ | ○ | ○ | ○ |
Print-ready appeal letter and No.10 envelopeOpen — no implementing organ is measured for this axis yet. Window-zone tri-fold letter plus envelope PDFs ready to print and mail | ○ | ◐ | ○ | ◐ | ◐ |
Local-first privacy: bill data never leaves the machineMeasured exceed:PRIVACY in runtime/nx_fin_dispute.nx, verified at emit. Patient and provider specifics are caller-supplied and never enter web queries; all four rivals are cloud PHI processors Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ◉ | ○ | ○ | ○ | ○ |
Fail-safe execute: can never auto-sendMeasured exceed:NEVER-BRICK in runtime/nx_fin_dispute.nx, verified at emit. disp_build writes only a caller buffer with no socket or file send; human reviews and sends Adoption: LIB-WIRED importers=3 nonval=2 — fully adopted (top of its ladder). | ◉ | ○ | ○ | ○ | ○ |
CPT HCPCS ICD lookup with plain-English decodeMeasured:mbc_get exists in runtime/nx_medbill_codes.nx, verified at emit. M1 live: official NLM ICD-10 and HCPCS descriptors ingested sovereignly, curated CPT with visible provenance, unknown codes refuse Adoption: LIB-WIRED importers=9 nonval=3 — fully adopted (top of its ladder). | ● | ◐ | ● | ● | ● |
Automated coding from clinical textOpen — watchingruntime/nx_medbill_autocode.nx : mbac_suggest, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. The LLM-coding frontier; provider-side | ○ | ○ | ○ | ◐ | ◐ |
Claims denial prediction and preventionOpen — watchingruntime/nx_medbill_denial.nx : mbd_score, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. Waystar's AI denial management is its flagship pitch [waystar] | ○ | ○ | ○ | ◉ | ◐ |
Prior-authorization automationOpen — watchingruntime/nx_medbill_priorauth.nx : mbpa_draft, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. The burden the field is racing to automate | ○ | ○ | ○ | ◉ | ◐ |
EDI X12 837 835 clearinghouseOpen — watchingruntime/nx_medbill_edi.nx : mbe_parse, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. Waystar is a clearinghouse; Tebra rides one [tebra] | ○ | ○ | ◐ | ◉ | ● |
Eligibility and benefits verificationOpen — watchingruntime/nx_medbill_elig.nx : mbel_check, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. Real-time 270 271 checks [cms-x12-transactions] | ○ | ○ | ◐ | ◉ | ● |
Hospital price-transparency file ingestOpen — watchingruntime/nx_medbill_prices.nx : mbp_ingest, re-measured on every compare beat. Ship that symbol and this mark flips itself; the comparewatch- plane row flips with it. Turquoise built the business on MRF ingest; feeds our fair-price packs at scale [cms-price-transparency] | ○ | ◐ | ◉ | ◐ | ○ |
Patient advocacy portalMeasured:hh_page exists in runtime/nx_healthhelp_site.nx, verified at emit. M6 live: zero-JS no-PHI portal generated FROM the gated letter engines (single source), public at /factory/healthhelp; Goodbill still leads with accounts and negotiation service Adoption: LIB-WIRED importers=2 nonval=1 — fully adopted (top of its ladder). | ● | ◉ | ○ | ◐ | ◐ |
On these two registers. Rows are declared in the domain's plan file and carry the debt id, which is the join key back to the sovereign debt plane — that plane, not this page, is the authority on state. Reconciling them automatically (the regen reading the plane and refreshing these rows) is a named, owed rung; until it lands, treat an id here as a pointer to look up, not a status to trust.
Honest verdict. The coverage above is capability presence measured against source — not depth, scale, or polish, where mature rivals may lead. Exceeds are claimed only where a mechanism backs them. Every open gap is a watch contract: it names the organ and symbol that closes it, and this page flips the cell itself when that workstream ships.
Person · product · place — not yet measured for this domain
Every compare carries this layer. Declare
knowledge/compare/medbilling.ppp (rows surface|nishi or c1..c4|label|url|connect naming OUR live surface and each rival's front door), run nx_ppp_probe domain medbilling, and this section fills itself on the next beat: the same ruler on both sides — privacy and CX (third-party hosts, tracker classes, cookies, security headers), design and longevity (design hygiene, computed WCAG contrast, render-blocking resources, unsized media, script weight, theme and motion queries), findability (landmarks, skip link, on-site search, breadcrumb, headings, internal links).References
Beyond a link list. Every reference below resolves twice — the publisher's copy and, where banked, the estate's own non-rottable library mirror with a content pin — and carries its evidence class plus the exact claim on this page it grounds. Keyed marks like [key] in the matrix notes jump here. A dash means honestly absent, never assumed.
- [goodbill] Goodbill. Hospital bill review and negotiation on the patient's behalf (product surface), goodbill.com, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_goodbill.html· pinh40de741796e49bcc5b0fa4449747e39ae70ec527014d034df3bb753d35216b68· accessed 2026-08-18 · vendor-docGrounds: The Goodbill column: Best on 'Patient dispute and appeal letter generation' and 'Patient advocacy portal' (accounts plus a negotiation service the note concedes still leads), Part on the charity, appeal and NSA rows, and 0 on the local-first privacy row -- it is a cloud PHI processor. - [turquoise] Turquoise Health. Price transparency data platform built on hospital machine-readable files (product surface), turquoise.health, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_turquoise.html· pinh3ab0756286e12c6a4587397a72b8e963d30a2f68542f0808bf4198d71262ed5f· accessed 2026-08-18 · vendor-docGrounds: The Turquoise Health column: Best on 'Fair-price check vs Medicare benchmark' and 'Hospital price-transparency file ingest' -- the row note names Turquoise price data as the industry reference our multiplier knob is measured against. - [waystar] Waystar. Healthcare payments platform: clearinghouse, claims management, AI-driven denial prevention and appeals (product surface), waystar.com, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_waystar.html· pinhd2926c309e89db4e62094e43730b4f504b5579aa392a1f763fba43bcc4ca5388· accessed 2026-08-18 · vendor-docGrounds: The Waystar column: Best on 'Claims denial prediction and prevention' (the note calls its AI denial management its flagship pitch), 'Prior-authorization automation', 'EDI X12 837 835 clearinghouse' and 'Eligibility and benefits verification' -- provider-side capabilities we declare absent. - [tebra] Tebra (Kareo plus PatientPop). Practice-management, billing and patient-experience platform for independent practices (product surface), tebra.com, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_tebra.html· pinh51229793761d3a31bd93aecf68538c6eb6f9c4f0d6b0005364c6d05e9a5389ff· accessed 2026-08-18 · vendor-docGrounds: The Tebra column: Part on most audit and dispute rows and Yes on 'EDI X12 837 835 clearinghouse' via a clearinghouse it rides rather than owns, as the row note states. - [cms-ncci] Centers for Medicare and Medicaid Services. National Correct Coding Initiative (NCCI) Edits -- Procedure-to-Procedure edits and Medically Unlikely Edits (MUEs), cms.gov, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_cms-ncci.html· pinh24110c6895b408f424dfe8071b61c6bf15c7fd34f27d54e2aa2ef9a8bb209406· accessed 2026-08-18 · published-standardGrounds: The 'NCCI unbundling edits' and 'Medically-Unlikely-Edits over-units check' rows: the comprehensive-plus-component pair tables and per-code unit maxima nx_fin_audit loads as data packs are published here, which is why the pairs are data not hardcode. - [cms-nosurprises] Centers for Medicare and Medicaid Services. No Surprises Act -- surprise-billing protections for emergency and certain in-network-facility out-of-network care, good faith estimates and the patient-provider dispute resolution process, cms.gov, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_cms-nosurprises.html· pinhcc87ef7597046f7e18c251324a914bc03659c0ba27c165e092d9d4221d0a2ca3· accessed 2026-08-18 · published-standardGrounds: The 'No-Surprises-Act grounds cited in disputes' and 'NSA situation classifier and PPDR routing' rows: the emergency and in-network-facility protections and the uninsured good-faith-estimate dispute window nsa_classify routes to are the program described here. - [irs-501r] Internal Revenue Service. Requirements for 501(c)(3) Hospitals Under the Affordable Care Act -- Section 501(r): financial assistance policy, limitation on charges, and billing and collection requirements, irs.gov, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_irs-501r.html· pinhe5d53432f22758d28091b213ba50cf77b32e55cf01a02d8343192621e33b423f· accessed 2026-08-18 · published-standardGrounds: The 'Charity-care screening plus 501(r) FAP request' row: the financial-assistance-policy duty and the 501(r)(6) bar on extraordinary collection actions before FAP eligibility is determined, which the generated letter invokes as its collection hold. - [cms-x12-transactions] Centers for Medicare and Medicaid Services. Health Care Transactions Basics (Administrative Simplification): the HIPAA-adopted X12 transaction standards -- 837 claims, 835 remittance advice, 270/271 eligibility, 276/277 claim status, 278 authorization (PDF), accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_cms-x12-transactions.pdf· pinh513ddafc3b699839d1ae2f49c654bbbd71f487c41c4b7ff81b5c9489f8082b60· accessed 2026-08-18 · published-standardGrounds: The 'EDI X12 837 835 clearinghouse' and 'Eligibility and benefits verification' gap rows: the transaction sets those absent organs would have to speak (837, 835, 270/271) are the adopted standards enumerated in this CMS primer, which sizes the gap honestly. - [cms-price-transparency] Centers for Medicare and Medicaid Services. Hospital Price Transparency -- machine-readable standard-charge files and consumer-friendly display requirements under 45 CFR Part 180, cms.gov, accessed 2026-08-18. publisher · read in our library
knowledge/fetched/cmp_medbilling_cms-price-transparency.html· pinhba67c6b745e94e03488f5294832c7b952245ca08972c63629c3fdd645f061a9b· accessed 2026-08-18 · published-standardGrounds: The 'Hospital price-transparency file ingest' gap row and the 'Fair-price check vs Medicare benchmark' row: the machine-readable files Turquoise built its business on, and that our fair-price packs would ingest at scale, are the ones this rule requires hospitals to publish.
generated by nx_swcompare_matrix (sovereign NishiLang organ) from knowledge/compare/medbilling.matrix · every Nishi cell verified against organ source at emit time · watch cells re-measured on every compare beat · zero JS, zero trackers