One of the legal points revealed by NAHC attorney Denise Bonn last week was the requirement that Recovery Audit Contractors prepare a region with training about their planned activities before they can conduct audits in the region.
Two brief stories that have come to our attention here at RAC Assistance for Home Care are worth retelling.
A Tale of Two States
RACs and CMS may consider themselves quite independent and free to act unilaterally. The executive director of one western state home care association reports that an official RAC seminar was scheduled and publicized with no prior attempt to notify or coordinate with the association.
“We would have been happy to promote the session among our membership,” the Director said, “but we only heard about it ourselves by chance.”
In the opinion of one East Cost counterpart, that state may have been better off not knowing about the RAC training.
Sherl Brand, president and CEO of the Home Care Association of New Jersey, told RAC Assistance that she received CMS and RAC assistance to conduct a training in her state and has never in her career seen such low scores on post-presentation evaluations.
Brand decided to be proactive about educating her members. She approached her Regional Home Health Intermediary, NGS, and requested a home care-focused seminar.
“NGS was quite helpful,” she explained. “They directed me to Ebony Brandon and Gia Lawrence and said they were developing training programs for this region. They are both lovely people; they replied and said they would be happy to provide a program. ‘That’s what we’re here for,’ they said.”
“I was specific about what we were looking for, Brand continued. “We wanted a seminar that would focus on home care and hospice, explain how the program would impact us and tell us what we should do to prepare, maybe talk about on what issues the audits would focus. They agreed, said ‘no problem’ and mentioned they would include the local RAC contractor and its sub-contractor’. I advised them they should be prepared to address high-level professionals, persons involved with medical records, finance and billing.”
Brand and her contacts decided on an audio conference format and got good response from her New Jersey membership. According to Brand, the speakers consisted of two people from What those members heard was 45 minutes of six people each describing their own resumes and qualifications. After a Q&A session, the two-hour time slot was over in less than an hour.
“I am seriously considering refunding the registration fee to my members,” Brand said. “I could have read an article to get what we got. During the Q&A section, we learned the difference between Automated Audits and Complex Audits and that they will reimburse for mailing costs but, other than that, they did not know anything about home care and hospice, even though I had made it clear that is who would make up their audience.”
Brand remembers that every question from the listening audience was met with hospital-based answers and examples. “That was when they understood the question,” she continued. “The six presenters were two each from the RAC contractor, Diversified Collection Services, its parent company and CMS. None of the six seemed familiar with home care terminology when a question was asked. Someone wanted to know what coding guidelines would be used and they said they would get back to us on that.”
The presenters did provide printed materials, Brand acknowledged. “They were generic, things you could download from the CMS web site,” she added. “I offer a number of in-person and audio conference educational activities for my members every year. I have never seen evaluations as dismal as these.”
Sherl Brand
President and CEO
Home Care Association of NJ
(HC & H and certified)
all received same communication about RACs, and about opportunity to be educated. IN that regard, I went to NGS and then CMS to ask for point of contact they could refer me to so I could set up a program. NGS helpful, told me to contact Ebony Brandon or Gia Lawrence for thsi region. Lovely people, replied to me, happy to provide a program, that’s what we’re here for. I was specific about what we were looking for, focus on HC & H. How it would impact us, how it came to be, focus of audits, what can providers do to prepare, “OK, no problem. and we would like to include contractor and their sub.”
Set up audio conf. Good response from membership. I said these would be high-level people, involved in med records, review, billing, finance, savvy people. That is not what we got. I could have read an article to get what we got on audio. 6 people, 45 minutes, talked about own resumes. Q&A was of some value. I thanked them but was so disappointed. What came out is that they do not know HH & H because it was not part of the demonstration. Could not answer questions about HH & H. One was “what coding guidelines are you going to be using?” They said they would get back to us; gave hospital examples.
Materials were generic, things you could get from CMS web site. Helpful discussion about automated vs. complex review. 6 speakers from Diversified Collection Services and their parent and CMS. Will try to find underpayments and repay them too. Will reimburse for mailing costs.
Feedback: worst I’ve ever seen. Speakers did not seem to understand questions being asked them.
