RAC Updates
Amednews.com posted an article on Monday to discuss planned RAC audit expansions by the end of this year. The Patient Protection and Affordable Care Act requires CMS to include in the audit umbrella Medicare Advantage, the Medicare drug benefit and Medicaid in addition to the current Medicare design. The article notes that, “Earlier this year, President Obama called for expanding payment recapture audits throughout the federal government to improve payment accountability.”
The president and CEO of HealthDataInsights, the Medicare RAC for audit region D, also mentioned expansion into the Veterans Health Administration and Tricare. “To the extent that we can accelerate the national RAC program…speedy returns to the Medicare trust fund will be achieved,” she noted.
This expansion would certainly be a huge benefit to the government, but issues persist. Despite the looming Medicaid inclusion deadline, the director and CFO of CMS’ Office of Financial Management, Deborah Taylor, explained the difficulties they face in meeting that target. Indeed, she noted, “We are still in the planning stages,” due to the fact that there are 50 state programs in Medicaid with which CMS needs to coordinate efforts.
Still, with the Medicare overbill recapture dollars growing from $54 million in the first year to $247 million in the second, plus the promise to help fund the recent healthcare bill overhaul with such RAC audit programs, pressure on CMS will be intense to meet the required deadline. CMS has met some of the bill’s targets and are close to others. For example, the requirement to expand the Medicare RACs to all 50 states has been met, and Taylor asserted they are far along with implementing the prescription drug benefit into the program.
In response to physician complaints which arose during the demonstration phase of the RAC audits, CMS has added many changes to the Permanent RAC program. Amednews added a chart to the article that demonstrates those changes. I’ve copied it below:
|
Demonstration RACs |
Permanent RACs |
|
|
RAC medical director |
Not required |
Mandatory |
|
Coding experts |
Optional |
Mandatory |
|
Reviewers' credentials upon request |
Not required |
Mandatory |
|
Maximum claims look-back date |
None |
Oct. 1, 2007 |
|
Limits on medical records requested |
Optional |
Mandatory |
|
General RAC website |
Not required |
Operational since January |
|
RAC claim status website |
Not required |
Operational since January |
Source: Centers for Medicare & Medicaid Services Office of Financial Management
The bottom line is that the RACs are here to stay. In addition to seeking and charging with crimes the overtly fraudulent Medicare schemes, they are also going after the unintended overbills arising from simple coding errors and rule misunderstandings. Few specialties can surely be impacted by such audits as oncology, particularly with regard to Medicare. With the volume of Medicare patients oncologists see and the complicated coding rules, it would be wise to be prepared for such an eventuality.