So you got the notice...the Medicare RAC is reviewing your practice. Not worried? Think again. The CMS audit of all beneficiaries of Medicare payments...
So you got the notice...the Medicare RAC is reviewing your practice. Not worried? Think again. The CMS audit of all beneficiaries of Medicare payments (anyone who files medical claims with Medicare) is here to stay and if your practice is out of compliance,
it could end up costing you thousands of dollars. It's not all gloom and doom, however. Follow these few simple steps to help get your practice prepared.
A quick history of the Medicare RACs. In 2005 Congress authorized the Recovery Audit Contractor (RAC) program to do a demonstration in California, New York, Florida. The purpose - to discover areas of fraud and waste and recover overpayments made by Medicare due to improper coding and compliance with Medicare guidelines. The result - over $900 million in overpayments recovered and returned to the Medicare Trust Fund. Due to the success, Congress authorized the RAC program to be rolled out to all 50 states and Puerto Rico no later than January 1, 2010.
Don't count on it being temporary...this program is to be permanently in place.
Anyone who files claims with Medicare - doctors, hospitals, home health agencies and durable medical equipment providers are all affected. What does this all mean to you? If you belong to one of the above groups, be prepared to get a notice soon from the contractor in charge of the audit in your region. The RACs are compensated on a contingency basis based on the amount of dollars they recoup. You think they are going to be aggressive? You betcha! The penalties for being out of compliance? At the very least, overpayments will have to be returned. And Medicare isn't going to send you an invoice and wait for the money...they will take a portion of your current and future claims payments until the overpayment is paid in full. In extreme cases, Medicare may suspend a practice's claims privileges all together.
Here's how to make sure you are covered.
First, you may want to conduct an internal assessment of submitted claims to make sure they follow Medicare guidelines. Either you, your staff, or a third-party auditor can do this. However, a certified third-party auditor may be the best option as this allows for someone with an unbiased look to give you a second opinion. If you do choose to do it yourself, look for claims that have been denied in the past and review the CMS RAC website.
Think about having a certified coder take a look at a sample of your files and help you pinpoint any pattern of inconsistent or errors in coding. Again, a third-party audit service is an excellent option. A qualified auditor should have certified coders on staff, preferably with government auditing experience as well.
Comply with Medicare's request for medical records in a timely fashion. Not doing so may cost you the right to appeal any decisions by the RAC that are not in your favor.
Lastly, implement corrective measures to ensure compliance with CMS guidelines before the RAC visit to your practice. The sooner you do this, the less money you will cost yourself when the RAC visits you. If you choose to use a third-party auditor to help you, they should provide you with a report on areas for improvement as well as consult with you on other areas of compliance as well.
With the right preparation and implementation of processes, you don't have to fear the RAC. Besides, you may get some good out of your audit. During the same demonstration in the above mentioned states, $38 million in underpayments to providers was made. You may find areas where you have been underpayed, so there are positive opportunities as well.
