RAC Preparation Checklist

Similar documents
THE MEDICARE RECOVERY AUDIT CONTRACTOR (RAC) PROGRAM: An Evaluation of the 3-Year Demonstration

Anatomy of an Appeal. Fourth Medicare RAC Summit September 13-14, 14, 2010

FREQUENTLY ASKED QUESTIONS

Agenda. RAC Mission MAC s Medical Review MAC s Role in the RAC process Demand Letters and Collection Process Appeals Process Resources

RACs and Beyond. Kristen Smith, MHA, PT. Peter Thomas, JD Ron Connelly, JD Christina Hughes, JD, MPH. Senior Consultant, Fleming-AOD.

Medicare. Claim Review Programs: MR, NCCI Edits, MUEs, CERT, and RAC. Official CMS Information for Medicare Fee-For-Service Providers

Recovery Audit Contractors The Beginning to Now and Overview RACs Challenged by Providers? A Recent OIG Report May Be Indicating Just That 1 CEU

Recovery Audit Contractors (RACs) Reference Document Created by Elin Baklid-Kunz

Medicare Audit and Appeals: Practical Advice on Preparing for and Responding to RAC, ZPIC, and MAC Audits. February Overview

Zone Program Integrity Contractors (ZPICs), 2013 TEXAS HEALTH CARE ASSOCIATION SUMMER MEETING

Medicare Audit and Appeals: Practical Advice on Preparing for and Responding to RAC, ZPIC, and MAC Audits. February 2012

How To Appeal and Win a Medicare Audit

How to Submit an Appeal: The Redetermination Level

DRAFT Statement of Work for the Recovery Audit Contractor Program

Current Payor Audit Mechanics and How to Defend Against Them. Role of Office of Inspector General in Federal Audits

MMA Mandate: Medicare Contract Reform

How to Prepare for and Respond to RAC Audits. Kathleen H. Drummy, Esq.

Table of Contents. DME MAC Jurisdiction C Supplier Manual. Table of Contents. 1. Introduction

Compliance. What Every Coder Needs to Know

October 10, th Annual Ambulatory Surgery Center Conference Improving Profitability and Business / Legal Issues

Medicare Claims Appeals: From Audit to OMHA

Auditing RACphobia. Lamon Willis, CPCO, CPC-I, CPC-H, CPC AHIMA-Approved ICD-10-CM/PCS Trainer Xerox Healthcare Consultant

Medicare Claims Appeals Developments and Proposals for Expansion

Medicare Program Integrity Manual

Agenda. Key Terms. How to Effectively Manage A Medicare Audit. Welcome. The Basics. ADR Process Appeals. Record Submission Process Questions & Closing

RACs to ZPICs. Program Integrity Audits and the Ever Increasing Burden on Healthcare Providers. April 22, 2015 Claire Owens, JD

RAC Jurisdictions D B. March 1, March 1, August 1, 2009

Integrity Matters! Health Care Compliance Association (HCCA) Regional Dallas/Ft Worth (DFW) Conference Grapevine, TX February 15, 2019

IS YOUR PRACTICE A GOVERNMENT TARGET? A BRIEF REVIEW OF THE AUDIT PROCESS WHAT IS AN AUDIT?

Medicare Program Integrity: Overview and Issues

Region [Region #] Recovery Audit Contractor (RAC) Date: [Request Date]

E&M Utilization Analysis: Beyond Coding

Chapter 7 General Billing Rules

COMPLIANCE; It s Not an Option

RAC Audits, Extrapolation and Defensive Strategies

DMEPOS Audit Trends. Understanding the DME Audit Landscape. They re All Watching Licensing You YOU

Medicare Program Integrity: Activities to Protect Medicare from Payment Errors, Fraud, and Abuse

All the President s Men : Medicare Denials and Appeals

Passport Advantage Provider Manual Section 13.0 Provider Billing Manual Table of Contents

Medicare Accounts Receivable Management Strategies. Your Speakers

Third National Medicare RAC Summit

Transparency, Reporting & Data Mining

Comprehensive Application of Predictive Modeling to Reduce Overpayments in Medicare and Medicaid

MGMA Medicare Audits Fact Sheet

E&M Utilization Analysis. Frank Cohen, MBB, MPA, Director, Analytics Doctors Management LLC, Knoxville, Tenn.

SETTLEMENT CONFERENCE FACILITATION

CMS Audit Contractors

Frequently Asked Questions

Fraud and Abuse in the Medicare Program

From Legislative Authorization To National Implementation: The Key RAC Milestones, Results and Lessons to Date

5. Recovery Auditors shall perform the necessary provider outreach to notify provider communities of the Recovery Auditor s purpose and direction.

Navigating ZPIC Audits: Challenges and Solutions for Health Care Providers

Medicare Program Integrity Manual

Medicare Keeping Up With the Pace of Change. Presented by Medicare Part B Provider Outreach and Education 2017

The Part B Appeals Process

Medicare Program; Implementation of Prior Authorization Process for Certain

Medicare Program Integrity Manual

Center for Medicaid and State Operations/Survey and Certification Group

Medicare: Become an Expert in Less than an Hour!

Medicare Part A Quarterly Updates. Palmetto GBA JM A/B MAC Provider Outreach & Education September 13, 2017

WHAT IS AN AUDIT? IS YOUR PRACTICE A GOVERNMENT TARGET? An audit is a review of medical claims submitted to a government or private payer.

Anticipating Medicare's Alphabet Soup of Audit Contractors, Ranging from ZPICs and RACs to CERTs and MACs

CONTRACT YEAR 2018 MEDICARE ADVANTAGE PRIVATE FEE-FOR-SERVICE PLAN MODEL TERMS AND CONDITIONS OF PAYMENT

MEDICAL DEVICE REIMBURSEMENT PRESENTED AT ST. THOMAS UNIVERSITY, DESIGN AND MANUFACTURING IN THE MEDICAL DEVICE INDUSTRY COURSE ON SEPTEMBER 30, 2013

Improving Integrity in Nursing Centers

Defending Against Statistical Sampling and Extrapolation. April Anna M. Grizzle Bass, Berry & Sims PLC

New ZPIC Medicare Audits: Are You Ready? Preparing for Heightened CMS Enforcement Against Fraud and Abuse

Challenges in Maintaining a Laboratory Compliance Program

Payment Policy: Clinical Validation of Modifer 25 Reference Number: CC.PP.013 Product Types: ALL

Behavioral Health FAQs

ABN Requirements, Updates and Challenges from the ALJ Ruling

5/7/2013. CMS Part B Inpatient Rebilling Rules

Compliance Issues: Self-Disclosure, RAC Audits and Red Flags

CBR201606: Modifiers 24 & 25 General Surgeons

Glossary. Last Reviewed 11/10/14

HIPAA Electronic Transactions & Code Sets

Center for Medicaid and State Operations/Survey and Certification Group

Medicare Program Integrity: Activities to Protect Medicare from Payment Errors, Fraud, and Abuse

Lessons Learned from the ALJ Experience

RAC Appeals Settlement

FHCA 2012 Annual Conference Hilton Hotel Orlando, FL. CE Session #22 ZPIC Audits

CRCS Exam Study Manual Update for 2017

CMS Provider Payment Dispute Resolution Mechanism

Introduction to the Centers for Medicare & Medicaid Services (CMS) Payment Process

Prepared for state, metropolitan and regional hospital associations. Recovery Audit Contractor Program Update. May 28, 2009

Medicare Appeals for Health Care Providers: Understanding the Appeals Process and the Impact of the Backlog

Fidelis Care uses TriZetto's Claims Editing Software to automatically review and edit health care claims submitted by physicians and facilities.

interchange Provider Important Message

9/17/2018. Non-covered services. Description: Billing for services not covered under the Medicare program

Medicare Prescription Drug Coverage: How to File a Grievance, Request a Coverage Determination, or File an Appeal

Blueprint for a Successful Audit Strategy

Avenues of Resolution for Indiana Health Coverage Programs

Medicare Advantage Private Fee-for-service Plan Model Terms and Conditions of Payment

ZPIC, RAC, HIPAA AUDITS IN LTC: ARE YOU READY?

Unified Program Integrity Contractor Request for Information (RFI) Requirements Document

ReedSmith. Part B Inpatient Billing in Hospitals. Client Alert. Life Sciences Health Industry Group

HEALTHCARE COMMON PROCEDURE CODING SYSTEM (HCPCS) LEVEL II CODING PROCEDURES

Office of Compliance Services. Revenue Cycle and Billing Terminology and Definitions

There is nothing wrong with change, if it is in the right direction Winston Churchil

C H A P T E R 8 : Billing on the CMS 1500 Claim Form

Transcription:

RAC Preparation Checklist A. Select an internal RAC Team using individuals from key departments and identify individual roles (if any) in the RAC process. Communicate each individual s roles to others involved in the RAC process. Senior leadership Finance/revenue cycle Clinical documentation management Coding Case management/care coordination Business office (operations, and denials management) Information technology (IT) support services Clinical departments Legal (internal and external) B. Identify and distribute important contact information for RAC audit. Identify the individual in your organization who will serve as the primary RAC point-of-contact ( POC ) and secondary POC. Educate employees about who to contact upon receipt of RAC correspondence. Know the RAC contact information. The contact information for HDI is: https://racinfo.healthdatainsights.com/public1/contact.aspx Develop and distribute list of external contacts e.g., legal, consultants, accounting. C. Develop tracking and appeals process. Establish a system and identify individuals responsible for tracking medical records requests ( ADRs ) and maintaining copies of the medical documentation submitted to RAC. Instruct individual(s) responsible for tracking and maintaining RAC correspondence to maintain all original correspondence and envelopes. Develop/use RAC Appeal Timeline to keep track of deadlines. Establish system for reviewing adverse results (i.e., who reviews each case, involvement of outside legal counsel or consultant, sequence of review, ultimate decision-maker).

RAC Issues Checklist Issues to consider when reviewing a RAC Demand Letter and the RAC s reasons for determining there was an overpayment: Does the RAC allege an overpayment for claims paid over three calendar years prior to the date of the record request (complex medical reviews) or the date of the overpayment notification (automated review)? RACs may not review such claims. Does the RAC allege an overpayment based on claims previously reviewed by another Medicare contractor, such as a Program Safeguard Contractors, Quality Improvement Organizations (QIO) or Comprehensive Error Rate Testing (CERT) program contractor? RACs may not review such claims. Does the RAC base its overpayment determination on an issue that is not a RAC-approved issue? Each RAC issue must be approved before implementation. The chart of RAC-approved issues for Washington State can be found at: https://racinfo.healthdatainsights.com/public1/newissues.aspx?state=wa Is the authority the RAC cites for its decision (e.g., Medicare Manual provision, coding policy, Local Coverage Determination) applicable to the claim at issue? The right hand column of the chart of RAC-approved issues (website above) cites the relevant authority for each RAC-approved issue. Does the RAC apply the correct version of the authority (e.g., Medicare Manual provision, coding policy, Local Coverage Determination)? Is there other Medicare guidance, newsletters or policies that conflict with the authority the RAC applies to the claim? Does the RAC base its overpayment determination on alleged dating or signature errors? Dating errors and failure to sign documentation does not mean there has been an overpayment. Does the RAC base its overpayment determination on an alleged off-label use of a drug or failure to comply with dosage/ administration requirements? Off-label use of a drug does not mean there has been an overpayment. Does the RAC base its overpayment determination on failure to comply with physician supervision requirements? Consider gathering patient appointment schedules, physician schedules, staff testimony establishing physician s presence in the office on the date at issue.

Common RAC Acronyms ALJ: Administrative Law Judge CERT: Comprehensive Error Rate Testing program CMD: Contractor Medical Director (for RAC) CMS: Centers for Medicare and Medicaid Services CPT: Current Procedural Terminology DHHS: Department of Health and Human Services DME: Durable Medical Equipment DOJ: Department of Justice DRG: Diagnosis Related Group ERRP: Error Rate Reduction Plan FFS: Fee for Service HCPCS: Healthcare Common Procedure Coding System HIC: Health Insurance Claim IRF: Inpatient Rehabilitation Facility LCD: Local Coverage Determination MAC: Medicare Administrative Contractor MMA: Medicare Prescription Drug, Improvement, and Modernization Act of 2003 MSP: Medicare Secondary Payer MRN: Medicare Redetermination Notice NCD: National Coverage Determination NPI: National Provider Identifier OIG: Office of Inspector General OMB: Office of Management and Budget PSC: Program Safeguard Contractor QIC: Qualified Independent Contractor QIO: Quality Improvement Organization RAC: Recovery Audit Contractor ROI: Release of Information RVC: RAC Validation Contractor SNF: Skilled Nursing Facility ZPIC: Zone Program Integrity Contractor

RAC Process No Automated Review RAC makes a claim determination RAC decides whether Medical records are Required to make determinations CMS New Issue Approval Process New Issues posted to RAC provider website once CMS-approved (may request records for new issue process not posted to web site) Yes Complex Review RAC requests medical records Provider has 45 days plus 10 calendar days mail time to submit. RAC has up to 60 days to review medical records RAC makes a claim determination RAC issues Review Results Letter to provider (does NOT communicate improper amount or appeal rights including no findings ) CMS Provider MAC RAC If no findings STOP

RAC Process Automated Review Discussion Period Carrier/FI/MAC Day 1 RAC sends claim info to Carrier/FI/MAC adjusts & issues Remittance Advice (RA) to provider. RAC issues Demand Letter which includes amount and appeal On Day 41, Carrier/FI/MAC recoups by offset. Code N432 rights. Complex Review Discussion Period Provider can pay by check by day 30 or request early recoupment from MAC to avoid interest. Provider can appeal by day 120. Appeal by day 30 will hold recoupment although interest is charged unless outcome is provider favor. CMS Provider MAC RAC