AMCNO Sponsored Recovery Audit Contractor (RAC) Seminar a Sell-out Event

On September 9th Dr. Laura David, AMCNO president-elect, welcomed a capacity audience of physicians and office managers to the AMCNO Recovery Audit Contractors (RAC) seminar. Dr. David spoke briefly about membership in the AMCNO and how it helps care for the unique interests of physicians in Northeast Ohio. She then introduced the evening’s speakers Dave Valent, Esq. and Jim Peters, Esq. of Reminger Co L.P.A.

Are you RAC ready? The evening began by Mr. Valent providing the background and history of Medicare reimbursements and the current process CMS uses with its program safeguard contractors (Advance Med) to audit healthcare providers. He went on to explain the future changes coming with the RAC program and highlighted some differences between the current program and the RAC program with one major difference being that RACs are paid a contingency fee for every dollar collected, i.e. a recovery of $1 million gives the RAC 12.5% return or $125,000. This provides a huge incentive for RACs to identify overpayments to providers and noted inpatient hospitals are an easy target with their computer records and such a high dollar potential.

Another difference is the recovery process between the current and RAC programs. An advantage under the new program is that providers will enter into a 30-day discussion period to contact CGI, the Ohio RAC, during which they can submit evidence about their billing practices. The appeal process also was explained should a provider disagree with the RAC’s determination. Overall the provider’s burden is minimized under the new program with a limit on the “look back period” of three years.

The RAC website is supposed to post information obtained from audits in an effort to warn and educate providers about mistakes. As of this time, the Ohio RAC website it not up and running. 

The presentation informed attendees about what they can do to get ready:

• Know where previous improper payments have been found.

• Know if you are submitting claims with improper payments by conducting an internal assessment to identify if you are in compliance with Medicare rules. Then identify corrective actions to implement for compliance. Make sure to not only focus on coding, but also on documentation so you can substantiate what you did. Consider having periodic compliance audits to proactively identify any problems. 

• Prepare to respond to a RAC medical record request by putting an action plan in place identifying specific steps to take when you receive a request, including designating a single contact person to speak with CGI.

• Appeal when necessary; only 14-16% of cases are appealed.

• Learn about the factors that trigger audits and safeguard against them, i.e. submitting codes outside of a specialty, submitting an increased number of claims, submitting claims beyond the national average for certain specialty area.

At the earliest, RACs are coming to Ohio as soon as October 2009 after completion of an educational program and will rollout with random automated reviews first, then complex reviews; however, the thought was that it could take until January 2010 to see any activity by the RACs.