Finance & Enjoyment Blog

RAC Audits Are Coming!

  • Have a sample of your claims reviewed by an outside coding expert.
     
  • Be sure your compliance manual is up to date.
     
  • Look for your most frequently used and highest dollar claims, and be sure coding is accurate. These will be among the first areas of RAC examination.
     
  • Monitor the RAC’s Web site for the items at the center of their attention, and scrutinize your practice for all that apply. CMS requires that RACs inform the public of specific areas of interest. Connolly’s Web site is: www.connollyhealthcare.com/RAC.
     
  • Consider any distinctive aspects of your practice (infusion therapy, sonography, etc.) and examine any that offer exposure for heightened RAC attention.
     
  • Assemble your audit response team, including a liaison physician, your highest ranking administrative staff member, and management/supervision staff from billing, coding, and document maintenance. Be sure your compliance manual has clear procedures that safeguard the practice, make revisions if necessary, and be sure that all team members, practitioners, and pertinent staff understand those procedures.  Notify your legal counsel of your preparations.
     
  • Require justification from the RAC continually throughout the audit. Photocopy the credentials of any RAC personnel that requests access your premises or records, and verify their ID with the RAC office.
     
  • Check your contact information on the Comprehensive Error Rate Testing (CERT) web site (from which RAC gets their information). Use this link to access/use the CERT provider address web site (pertinent regardless of your MAC):
    Be sure any communications from the RAC go directly to the appropriate party.  Now, if despite all your preemptive tactics you receive a RAC review request for records, activate your inner warrior -- it’s just the start of round two.
  • Scrutinize their sampling method; obtain their seed number, sample size, and universe size, and verify the sample via OIG’s RAT-STATs. Seek professional assistance, and know exactly what to ask.
     
  • Monitor deadlines. Preview any records to be sent to RAC; and retain copies of all materials sent. Document every communication (phone, letter, email, and voicemail, in either direction.)
     
  • Appeal every adverse ruling. (You should already be doing this now on every claim denial and every partial payment.)
     
  • Be sure to pay particular attention to E&M coding levels. Though not among RAC’s top priorities now, they are complex, controversial, and very high volume. RAC can review retroactively up to three years prior; therefore, offering extreme exposure via extrapolation.

    RACs can, and have been, successfully challenged on repayment amounts that have been reduced to fractions of initial RAC assessments.  Be bold and let it be known that you are here for the fight, and that you are not intimidated.
Aggressive positioning and preparation preceding RAC interaction; then challenging every step of the inquiry process, will minimize financial impact on administrative costs of countering a RAC investigation.  For a successful appeal you will collect 12 percent interest on amounts improperly withheld.


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