Late last year, the Centers for Medicare & Medicaid Services delayed implementation of the Recovery Audit Contractors program due to protests that were filed. On Feb. 4, the protests were settled and CMS will now continue RAC program implementation. The new RAC for Region D, which includes Oregon, is HealthDataInsights, Inc. of Las Vegas, Nevada. The program is scheduled to come to Oregon in August of this year.
As reported in past issues of STAT, the goal of this RAC program is to review physician and other health care provider claims to identify underpayments and overpayments and to recoup overpayments for the Medicare Fee-For-Service Program. The RACs will be paid on a contingency fee basis on both the overpayments and underpayments they find.
CMS suggests that physicians prepare for the start of the program by conducting an internal assessment to ensure that submitted claims meet the Medicare rules. Other steps to consider include:
- Identifying where improper payments have been persistent by reviewing the RAC website and identifying any patterns of denied claims within their own practice or facility.
- Implementing procedures to promptly respond to RAC requests for medical records.
- If the physician or health care provider disagrees with the RAC determination, filing an appeal before the 120-day deadline.
- Keeping track of denied claims and correcting these previous errors.
- Determining what corrective actions need to be taken to ensure compliance with Medicare’s requirements and to avoid submitting incorrect claims in the future.
The OMA will work closely with the AMA and CMS to identify how to best prepare physicians and their staff for this process. The OMA, along with other medical associations, also sent a letter to CMS stating their concerns regarding the RAC program. To read the full RAC program update, visit the CMS website at www.cms.hhs.gov/RAC/.
