The Patient Protection and Affordable Care Act (aka the health care reform bill currently under consideration by the Senate) has implications for the RACs. Of most relevance in this 2074 page bill is Section 6411 which seeks to expand RACs to Medicare Parts C and D by 12/31/2010. The RAC program would also be expanded to Medicaid. The Medicaid RACs, like the current RACs, would be charged with identifying and recovering overpayments and would be paid on a contingency basis. States will be required to contract with one or more RACs to identify overpayments. States will also need to have an adequate appeals process in place for providers to contest overpayment determinations. Given the complexity of Medicaid and the variations from State to State, this is likely to be quite a mess. It is not certain whether this bill will pass in the Senate nor how it might be amended. Nevertheless, the fact that the government is seeing to expand the reach of the RAC program even before the current RACs are up to speed indicates the confidence the government has in the likely effectiveness of the program. (more…)
Now is a good time to determine your hospice’s level of risk exposure to overpayment recoupment from your RAC. Although the RACs have not kicked in yet and may not for several more months, conducting an assessment now can give you a better sense of how vulnerable your hospice might be and how much you need or do not need to be worrying about the RACs. It can also help in the ongoing challenge of safeguarding against ADR claim denials and unsuccessful appeals.
Here are some considerations for assessing your risk level: (more…)
Connolly Healthcare, the RAC for Region C, is again leading the RAC pack in getting CMS approval for issues to review. This week Connolly posted two issues for DME providers. Click here if you are interested in seeing the description of these issues. Diversified Collection Services, the RAC for Region A, continues to be the only RAC that has not posted any issues at all.
The other RAC news of any interest this week is that the Frequently Asked Questions (FAQ) on the CMS RAC web page was updated. This is a helpful resource and can be seen here.
There is still not too much activity at the RAC Forum and there may not be until RACs begin targeting hospices. Nevertheless, we have added a new topic/category to the RAC Forum that we hope will be helpful. It is called “Claim Denial Reasons.” At the moment we do not know what issues the RACs will review for hospices but it is likely they will be similar to what RHHIs have reviewed in the past. At Weatherbee Resources we have noticed an increase in spurious reasons for claim denials with our ADR clients. Given the concerns about RACs overreaching as well, we thought it might be a good opportunity to begin gathering information about this from other hospices. The advantage is that together we can begin to think about strategies for appealing these denials, seek advocacy from NHPCO, or, if nothing else, rant about how unfair or bizarre things have become.
This article has been posted on two sites: homehealthnews.org and racassistance.com. Leave your comments and stories of your experiences at either site and Heather Wilson and Tim Rowan will consolidate them and keep track of important news that should be shared industry-wide.
The RACs have not yet begun targeting hospices and may not until 2010. Why should hospices worry about them? No one knows at this point how intense the RAC scrutiny of hospices will be. Could all this RAC concern be a case of much ado about nothing?
Maybe, but probably not. Let’s look at some of the things we know and some of the concerns:
RACs are not a myth.
Four regions have been designated and RAC contracts for each region have been awarded. (more…)
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by Heather Wilson
There is not much new since the update last week so we will provide a recap of the current status of each RAC.
For Region A, Diversified Collection Services is the only RAC that has not posted any approved issues on its website and therefore has not begun any automated reviews. (more…)
by Heather Wilson
I had the opportunity to speak with a hospice executive director this week who stopped by the Weatherbee offices for a visit during her vacation/workshop on Cape Cod. She talked about how challenging it is to keep up with issues like the RACs given the amount of information she needs to absorb and process each day. We also received a number of emails this week in response to the last e-newsletter asking us why we are focusing so much attention on the RACs and why they are important. I thought perhaps a broad RAC overview in organized sound bites might be helpful. (more…)
How to manage is the third component of the P-E-M approach to dealing with RACs. It may be inevitable that hospices, perhaps yours, will eventually receive a demand letter or request for records from the contractor at work in your region. As soon as a communication from a RAC is received, time is of the essence. Hospices need to have in place a “RAC S.W.A.T. Team” that can mobilize immediately, prepare clinical records for review, make decisions regarding whether or not to appeal and implement a timely, comprehensive response to management of RAC activity. Part of the response to RAC activity must include navigating the Medicare appeals process through each level in as efficient and cost-effective a manner as possible.
An equally important RAC management activity will be to monitor what they are doing across the country. Given how these for-profit companies are compensated (the more money they recoup from providers, the more money they make), the potential for RAC abuse or overreaching is worrisome. To help everyone’s monitoring efforts, RAC Assistance for Hospice has developed a RAC Forum where registered users can share their experiences and learn from each other about RAC activities in their own and other regions.
The RAC Forum will be the place where readers can tell colleagues what types of reasons are provided for recoupments, success or lack of success at various levels of the appeals process, etc. Please help RAC Assistance for Hospice help you by registering for and contributing to this forum. The more information we can gather, the more we will be able to monitor the activities of each RAC and ensure that they are not abusing the enormous power that has been entrusted to them.
The articles and resources in the Manage category of RAC Assistance for Hospice are intended to help hospices develop a comprehensive management response to RAC activity.
The very best, and maybe only, defense against Recovery Audit Contractor attacks against your payments is education. The P-E-M strategy for dealing with RACs focuses on education on two levels:
- Learn everything possible about what RACs do, who they are and what to expect from them; and
- Make absolutely certain that all of the hospice’s clinical staff knows how to assess patients for eligibility (for hospice care and for higher levels of care such as general inpatient and continuous care) and how to appropriately and thoroughly document that eligibility.
The articles in this newsletter’s Educate category of RAC Assistance for Hospice address these two areas: education about the RACs and about documentation.
