CMS Record Request Limits Increased

The CMS, bending to the RAC blood suckers, has set an increase in the maximum number record requests every 45 days from 200 to 300 starting April 1, 2010 (April Fools anyone?).

Additionally, the CMS is making more clear how they define an organization of more than 1 phycisian – take heed all ye who live by the mantra “this is a hospital issue” – why would the CMS clarify – nay – expand their definition of a physicians group is this was merely a hospital issue.

Here a breakdown of the update from CMS – definitions are below (Read the actual update yourself here):

  • Campus Unit – this really only affects practices with multiple locations.  As long as you have a single physical location OR your other locations are nearby – the first 3 digits of the zip code are the same.
  • Request limits are bases on 1% of all claims submitted (including Professional Services), it does not mater if the claim was paid out or not, but that total number submitted.
    • Remember: a RAC can hit you up every 45 days
    • Also this gem – “the RAC may exercise discretion in the exact composition of an additional documentation request” – meaning the RAC can go after any part of your business, no matter what percentage overall of your practice it is.
  • 2 limit caps in FY2010 (no need to simplify things):
    • Through March 2010 the limit is 200 ADR’s every 45 days
    • Starting April 2010 the limit goes up to 300 ADR’s every 45 days.
    • Sparkling gem #2:
      • “in FY 2010 CMS will allow the RACs to request permission to exceed the cap”

CMS – Centers for Medicare & Medicaid Services
ADR – Additional Documentation Request
RAC – Recovery Audit Contractor
FY – Fiscal Year