RAC Appeals and Reports to Congress

In the previously mentioned article on CMS Manual System changes, I touched on the fact that you need to be organized.

There is a second part to that CMS Manual change, and it deals with Monthly Appeals Reports and the proper method a RAC is to follow when they submit those reports.

About a year ago, I gave a presentation at a regional health meeting about HIPAA.  Prior to my speaking, there was a quick Q & A about a thing called a RAC Audit. I listened in shock as person after person described their method of tracking demand letters and files.   I heard spreadsheets, post-it notes…you name it.

When I got up to speak I couldn’t begin on my subject until I clarified a few items.  The first thing I did was ask: “how much time do you spend tracking this information?”

My answer wasn’t anything specific, but what occured was a low rumble, a murmur of gripes and complaints about how much time they spent.

My next question was: “how much value do these files have to your practice?”

That answer was much more specific as nothing less than “thousands of dollars” was yelled out.

I scribble a few notes to myself…and myRACTracker was born.

Here is the problem: as with almost all government programs, the RAC program is anything but simple.

And just like an insurance company, the last thing the RAC program wants to do is make it easy for a provider to appeal and KEEP their money.

For something as important and valuable as these files to be tracked on a spreadsheet or some other willy-nilly way shook me to my core.

Now we see the CMS want RAC’s to submit spreadsheets of appeals data to be used as reference for reports to Congress…SPREADSHEET!

There is mention in the manual update that this is until the RAC Data Warehouse is capable of tracking appeals, then they’ll “just” have to update that system instead.

These spreadsheets are going to be a confusing disaster.  It will probably take at least 2 full time employee at each RAC to generate these spreadsheets.

This is important stuff, and if you treat it like any other “thing” that needs to be followed, you are going to loose big time.

There are so many time line requirements to keep track of, you will lose your mind.

Nobody on the CMS side is looking to make this easy for you.

We are.

MyRACTracker.com will return sanity to your life, reduce the stress of your staff and let you actually see the value of the files the RAC’s request of you.

Not only will you be able to easily track everything RAC, you’ll be able to look at the system and instantly see how much money you have on the line.

You’ll see:

  • Total value of all files in review
  • Total amount of money recouped by the RAC
  • Total amount you have prevented the RAC from taking
  • There is much more to it, but money is really what this comes down to

Be smart and get on the waiting list to be a myRACTracker.com user.

No RAC Delay in Kentucky

Due to some posturing by contractors to gain the very lucrative RAC contract, there was expected to be a delay of when the newly awarded contractor would take over conducting RAC audits.

There may still be a 90 day RAC blackout period if/when a transition of the RAC contractors occurs, but that won’t be known until later.

Quite frankly, you should care one bit about this blackout period.

You should be preparing like you’ll receive a RAC letter tomorrow.

Ensure you back office is trained well.

Hire somebody to conduct a small sample RAC Audit to see what the condition of your practice really is.

Be ready to track every RAC file and letter you receive.

World’s Greatest Fishing Expedition

Randy Schultz a health lawyer in Kansas City says of the RAC process in Kansas City, “It’s the world’s greatest fishing expedition is what it is.”

Jacqui Stanard, a health insurance specialist in CMS’s Kansas City regional office said audits officially began in the area in August of 2009.

But it took through the end of the year for the contractor — Las Vegas-based HealthDataInsights Inc. — to ready the computer program needed to run automated reviews of billing records.

She also noted:

The audits began with hospitals and other inpatient facilities and are starting to migrate to physicians’ offices.

Let’s take a look at this time line for a moment.

Audits officially began in August 2009…but, due to computer issues, the RAC didn’t actually start audits until the beginning of 2010.

It is now early April.

So, even if audits did begin in August of 2009, 8 months into this, they are beginning to tap physician’s offices.
That didn’t take long.

This article further notes:

Schultz’s frustration stems from cases such as the one he had with an orthopedic practice, which he said got flagged for billing Medicare for knee braces delivered to patients while they were in the hospital. The auditor said the hospital should have billed for the braces, even though the practice bought them.

“So,” he said, “that little subtlety right there caused the RAC audit to demand a refund.”

Another Kansas City attorney said the following:

Ross said her experience thus far has been that the audits have been catching obvious billing mistakes by providers.   The danger with the slow rollout is that it might cause providers to let down their guard. That would be a mistake, Ross said.   “The impact has been slower than expected,” she said. “That does not mean it’s going away.

Let me repeat that last sentence: “the impact has been slower than expected…that does not mean it’s going away.”

That should echo in your head for a while.

It is time to get ready…it will be ugly.