Home care and hospice can breathe easy for a while, but only about this one issue.
Recovery Audit Contractors (RAC) are limited in the issues they can use to recoup funds from Medicare providers. It is important that all providers learn what those issues are and keep themselves updated as they change.
Initially, RACs may only look for overpayments and underpayments resulting from issues that arose during the 3-year demonstration project. Since home care and hospice were not addressed during the demonstration, those two healthcare segments are off the table when permanent contractors begin their search for improper payments.
RACs can add to the list of issues by applying for CMS approval. This is how home care and hospice will eventually be returned to the table and this is the reason compliance officers and revenue managers in these two segments must keep an eye on issue applications and approvals. This publication will do its best to help you.
Although a number of issues have been added to the base from the demonstration years, none of the RACs have announced CMS approval for home care or hospice issues. But they are getting close. A recent announcement by DCS Healthcare, the RAC for Region A, mentioned some Home Medical Equipment (HME) issues.
Here is a rundown of recent announcements:
Region A
Connecticut, Delaware, District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont
RAC: DCS Healthcare, San Angelo, Texas; www.dcsrac.com
Approved Issues: Pharmacy supply and dispensing fees when billed by a HME supplier; wheelchair bundling; urological bundling.
Region B
Minnesota, Wisconsin, Michigan, Illinois, Indiana, Ohio, Kentucky
RAC: CGI Technologies and Solutions, Inc., Fairfax, Virginia, outreach offices in Cleveland and Atlanta, www.racb.cgi.com
Approved Issues: Blood transfusions; IV-Hydration; Bronchoscopy services provided by outpatient hospitals and physicians in Indiana, Michigan and Minnesota only.
Region C
Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, North Carolina, New Mexico, Oklahoma, South Carolina, Tennessee, Texas, Virginia, West Virginia, Puerto Rico, U.S. Virgin Islands.
RAC: Connolly Healthcare, Philadelphia, Pennsylvania, www.connollyhealthcare.com/RAC
Approved Issues: Wheelchair bundling, urological bundling, Clinical Social Worker services (inpatient), blood transfusions, untimed CPT codes, IV hydration therapy (outpatient hospital and physician), bronchoscopy services, “once-in-a-lifetime” procedures (outpatient hospital and physician), pediatric codes exceeding age parameters, HCPC Code J2505 for injection, pegfilgrastim. Not all of the above apply to every state covered by Connolly. Each has been approved for a different group of 3-4 states.
Region D
Alaska, Arizona, California, Hawaii, Iowa, Idaho, Kansas, Missouri, Montana, North Dakota, Nebraska, Nevada, Oregon, South Dakota, Utah, Washington, Wyoming, Guam, American Samoa, Northern Marianas
RAC: HealthDataInsights, Inc., https://racinfo.healthdatainsights.com
Approved Issues: (these apply to all states covered by HDI) Neulasta; Newborn pediatric CPT codes billed for patients exceeding the age limit; Once-in-a-lifetime procedures; Excessive units – Untimed codes; Excessive units – Blood transfusions; Excessive units – Bronchoscopy; Excessive units – IV hydration.
Steps to take
- Find the web site for the RAC that serves your state or territory
- Bookmark it.
- Revisit the site from time to time or
- Sign up to receive regular email updates.
- Implement a charting training program that will improve documentation quality and, in effect, inoculate your agency against overpayment accusations.
- Relax. You have plenty of time. These contractors earn a commission on overpayments they recoup. It will be a while before they turn from deep pockets to shallow pockets.
- Spend your time more productively. You have far more imminent attacks against your revenue to worry about right now. See this week’s article about CMS shortening your timeframe for appealing payment denials. These denials are on the increase and are coming from your RHHI. Do not ignore them while focusing on some future, narrowly focused contractor limited to looking at tightly controlled issues.
