rac audits what you need to know

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Recovery Audit Contractors (RACs) Medicare, Medicaid and Commercial Insurance Investigations. What you Need to Know Brought to you by:

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If you are a Healthcare Provider or Office Manager in a healthcare setting, and bill fee for service, such as Medicare, you will be affected by the mandatory RAC audits. The audits are moving into full swing now.Will you be ready? This presentation will answer your questions and help you to prepare.

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Page 1: Rac Audits What You Need To Know

Recovery Audit Contractors (RACs)

Medicare, Medicaid and Commercial Insurance Investigations.

What you Need to KnowBrought to you by:

Page 2: Rac Audits What You Need To Know

Agenda What is a RAC & the Recovery Audit Contract? Mission of the government Contractors? What does the RAC do? How does the RAC affect providers? How do Providers Prepare? When the RAC arrives The Collection Process Providers Options What the other entities are saying

Page 3: Rac Audits What You Need To Know

What is a RAC?Recovery Audit Contractor-

“RAC”

Government awarded March 5, 2009:4 (Four) Private firms were awarded to perform medical records and billing

audits on providers in all 50 states and Puerto Rico.

Page 4: Rac Audits What You Need To Know

Why RACs & Who Has The Authority?

CMS was authorized to perform audits on all physicians, hospitals and allied health providers with the purpose of identifying:

Documentation and coding inconsistencies. Overpayments (& Underpayments) made to the providers based on the findings. Clear documentation to support the medical necessity of the services being provided or dispensed.

Medicare (CMS) was authorized by Congress with the following legislation:

• Medicare Modernization Act, Section 306: Required the three year RAC demonstration

&

• Tax Relief and Healthcare Act of 2006, Section 302: Requires a permanent and nationwide RAC program by no later than 2010.

Both Statutes gave CMS the authority to pay the RACs on a contingency fee basis.

The RAC demonstration identified $1.3 billion in overpayments in 3 states in ONE year

(California, New York and Florida Hospitals only)

Page 5: Rac Audits What You Need To Know
Page 6: Rac Audits What You Need To Know

The RAC Program Mission

• The RACs detect and correct past improper

payments so that CMS and Carriers, FIs, and

MACs can implement actions that will prevent

future improper payments:

• Providers can avoid submitting claims that do

not comply with Medicare rules.

• CMS can lower its error rate.

• Taxpayers and future Medicare beneficiaries

are protected.

Page 7: Rac Audits What You Need To Know

What does the RAC do?

RACs review claims and medical records on a post payment basis.

RACs use the same Medicare policies as Carriers, FIs and MACs: NCDs, LCDs and CMS Manuals.

RACs are required to employ a staff consisting of nurses, therapists, certified coders, and a physician CMD.

Collect overpaid claims. RACs will not be able to review claims paid prior to

October 1, 2007.

RACs will be able to review medical records three years from the date the claim was paid.

Page 8: Rac Audits What You Need To Know

Will the RACs affect me?

Yes, If the providers bill Fee-for-Service programs, such as Medicare, Medicaid or Commercial Insurance programs, your claims will be subject to review by the RACs.

If so, when? The expansion schedule can be viewed at :

www.cms.hhs.gov/rac

Page 9: Rac Audits What You Need To Know

Regions and timelines

D

C

B

A

March 1, 2009 March 1, 2009 March 1, 2009

March 1, 2009 March 1, 2009 March 1, 2009

August 1, 2009 August 1, 2009 August 1, 2009

Provider Outreach Claims Available for Analysis Earliest Correspondence

*RACs are required to perform outreach programs for all providers in their region

From CMS

Page 10: Rac Audits What You Need To Know

CMS RAC Review Phase–in Strategyas of 6/24/09

Earliest Possible Dates for reviews in Yellow/Green states:

Automated Review-

Black & White Issues- ( June 2009 )

DRG Validation- complex review

( Aug/Sept 2009)

Complex Review for Coding Errors- ( Aug/Sept 2009)

DME Medical Necessity Reviews-

complex review (Fiscal year 2010)

Medical Necessity Reviews-

complex review (calendar year 2010)

Earliest Possible Dates for reviews in Blue states:

Automated Review-

Black & White Issues- ( Aug 2009 )

DRG Validation- complex review

( Oct/Nov 2009)

Complex Review for Coding Errors- ( Oct/Nov2009)

DME Medical Necessity Reviews-

complex review (Fiscal year 2010)

Medical Necessity Reviews-

complex review (calendar year 2010)

Page 11: Rac Audits What You Need To Know

Fiscal Year 09

Medical Record Limits

Physicians Sole Practitioner: 10 medical records per 45 days per NPI. Partnerships: (2-5 individuals): 20 medical records per 45 days

per NPI. Groups (6-15 individuals): 30 medical records per 45 days per

NPI. Large Group Practices (16+ individuals): 50 medical records per

45 days per NPI.Other Part B Billers (DME, Lab Outpatient Hospital.)

1% of the average monthly Medicare claims (max 200) per NPI per 45 days.

Inpatient Hospital, IRF, SNF, Hospice 10% of the average monthly Medicare claims (max 200) per 45 days

per NPI.Other Part A Billers (HH)

1% of the average monthly Medicare episodes of care (max 200) per 45 days per NPI.

Page 12: Rac Audits What You Need To Know

How We Prepare Providers

Perform a baseline audit to:

• Identify improper coding and billing that is based on documentation in the patients medical record

• Assist the providers with training programs that can ensure they are meeting documentation compliance

• Available to assist the office in the event that the RAC communicates an audit

Page 13: Rac Audits What You Need To Know

How Providers Get Prepared

• Perform an independent assessment to identify areas of non-compliance with Medicare/Medicaid rules.

• Identify any corrective actions required for compliance.

• Implement any required changes to stay in compliance.

Page 14: Rac Audits What You Need To Know

Provider Self Disclosures

If a provider does a self-audit and identifies improper payments, the provider should report the improper payments to their claim processing contractor.

If the claim processing contractor agrees that they are improper, the claims will be adjusted and no longer available for RAC review (for that issue).

Page 15: Rac Audits What You Need To Know

Importance of Documentation Compliance

The medical record or chart notes must be complete & legible and must match the codes you submit- Evaluation & Management (office visit) Diagnosis Injections Supplies

Medical Necessity must clearly state the need for all services provided or prescribed. The documentation of each patient encounter should include: Reason for the encounter and relevant history, physical examination findings

and prior diagnostic test results; Assessment, Clinical Impression or Diagnosis; Plan for care; and Date and Legible identity of the observer

Page 16: Rac Audits What You Need To Know

Beyond the BaseLine Review

• Billing team must track all denied claims

• Identify all the issues• Look for patterns• Deploy any corrective actions

to avoid improper payments

We Can Be Your Solution

Page 17: Rac Audits What You Need To Know

When the RAC arrives Must provide a clear response to the letter within 45 days. Retain a certified coder to review the records prior to submission. Send copies of the charts to the RAC- signature required notification

of receipt. Digitized/electronic file of your charts and supporting documentation.

› RACs will accept imaged medical record on CD/DVD (CMS requirements coming soon).

Follow Up!› When necessary, check on the status of your medical record (Did

the RAC receive it?)› Call RAC› Use RAC Claim Status Website- no later than 01/01/2010.› Watch your mail for Detailed Review Results Letter following all

complex reviews.

Page 18: Rac Audits What You Need To Know

RAC Contact Information Website - E-mail - Telephone Number

Region A: Diversified Collection

Services www.dcsrac.com [email protected]

Region C: Connolly Consulting

www.connollyhealthcare.com/RAC

[email protected]

1-866-360-2507

Region B: CGI

http://[email protected] 1-877-316-7222

Region D: Health Data Insights

http://racinfo.healthdatainsights.com [email protected] Part A: 866-590-5598 Part B: 866-376-2319

Page 19: Rac Audits What You Need To Know

Next Steps from the RAC

Part B Adjustment Process: RAC send files to the Carrier/MAC/DME MAC or associated data center.

Data center does their research & processing & makes their adjustments on overpaid claims .

Data center then creates an accounts receivable for the adjusted claim & sends it back to the RAC

Upon receiving, RAC sends written notification to the provider of the overpayment , known as the “Demand Letter”, and researches any additional files that the data center notated other errors on.

• RAC will offer a discussion period- an opportunity to discuss the improper payment determination with the RAC. (This is outside of the normal appeals process.)

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Part A Adjustment Process:

• Basically same procedure except RAC sends written notification to the provider of the identification of an overpayment first .

• RAC sends an electronic file to the FI/MAC or associated data center.• FI/MAC or associated data center:

Does their research & processing & makes their adjustments on overpaid claims .

Send files back to RAC. Upon receiving, RAC researches any additional files when

necessary.

Page 22: Rac Audits What You Need To Know
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The Collection Process Recoupment of overpayments

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Demand letter comes from the (RAC)– Issue Remittance Advice

• Remark Code N432: “Adjustment Based on Recovery Audit”

– Recoups by offset unless provider has submitted a check or a valid appeal.

– Interest will accrue from the date of the final determination.

– Recoupment/payments are applied first to interest then to principle.

THEY TAKE THE $$$$ DIRECTLY FROM YOUR MEDICARE CHECK

Page 24: Rac Audits What You Need To Know

What Are Providers Options?

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If you agree with the RAC

Send check on or before Day 30 - do not appeal.

Recoupment by Medicare (overpayment + interest) on Day 41 and do not appeal.

Extended Payment Plan- Request or apply for extended payment plan

(overpayment + interest) and do not appeal .

Page 25: Rac Audits What You Need To Know

Appeal When Necessary

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If you disagree with the RAC The appeal process for RAC denials is the same as for

Carrier/FI/MAC denials Do not confuse the “RAC Discussion Period” with the Appeals

Process. Don’t stop with sending a discussion letter.

Pay by check on or before day 30 (interest is not assessed) AND file an appeal before the 120th day after the Demand Letter.

Allow recoupment (overpayment + interest) on Day 41 and file an appeal by Day 120

Request or apply for extended payment plan (overpayment + interest) and appeal by Day 120

Stop the recoupment by filing an appeal before day 31.

Page 26: Rac Audits What You Need To Know

What to Expect Next

Repeat the exact same process every 45 days

until they find no more overpayments

Page 27: Rac Audits What You Need To Know

Where do you turn?

Let Precision Billing & Cash Flow Solutions become your team of RAC Service Advisors. Have us …

• Get the Base Line Audit done as soon as possible.

• Determine where your practice will stand with the RAC team.

• Become the “go to” team for your practice when the RAC arrives.

Page 28: Rac Audits What You Need To Know

Other Payers Are Interested Too Medicaid (partially funded by the federal government and

managed by each state) They are hiring firms like Healthnet Federal Services

to mimic the identical issues as the federal government.

United Health, Aetna and other commercial payers Because they have implied authority to review all

providers claims

What they are saying...“If the providers are miscoding for Medicare they

are miscoding our claims also.”

Page 29: Rac Audits What You Need To Know

REVIEWThe RAC is serious- Providers need to know and

understand the implications.

Determine where the practice will stand.

Understand that you may need to call for help to manage the process.

Medicare is likely NOT the only payer going to take a peek.

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