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RAC - Where Are We Now

RAC (Recovery Audit Contractors) has continued to stay in the forefront of every practitioner and practice administrator's mind.  It also seems to have remainded at the forefront of the IRS' mind as well - 18,000 new agents have currently been assigned to this project.

RAC is continuing to prove itself to be not only profitable for the government, but quite a money making operation for the auditors who are able to receive payouts of 22.5% of the monies brought in through RAC audits.  Diversified Collection Auditors is the name of the New Jersey handlers group.

RAC was spawned off of the premise that it would minimize the burden on providers.  However, in 2008, during the pilot stage, RAC eased the burden to the tune of 17 billion dollars in collected refunds, and the pilot soon became the reality.

The Medicaid RAC program is due to be put into effect before 2011.

Although RAC has a look-back date of three years, meaning that is how far auditors can request charts dated from, with a show of "good cause" this period can be extended - back to the original date the practitioner enrolled in teh Medicare program.  RAC covers Medicare parts A, B, C, and D.

RAC does have specific request limits:

Solo practitioners are limited to 10 records every 45 days per group NPI number,  
Groups of 2 to 5 practitioners are limited to 20 records every 45 days,
Groups with 6 to 15 practitioners are limited to 30 records every 45 days, and
Groups with 16 or more practitioners are capped at 50 records every 45 days. 

For other Part B, the limits are:

1% of the average monthly Medicare services,
a maximum of 200 records per NPI number every 45 days.

RAC also has a specific Appeals Process.  This process is as follows:

Redetermination back to the contractor - 120 days
Reconsideration to QIC - 180 days
Administrative Law Judge - 60 days
Medicare Appeals Council - 60 days
Federal District Court - 60 days

One reason RAC is so successful is because practitioners do not challenge decisions.  Practitioners should take advantage of all RAC discussion periods.  They have forty-one (41) days from the intial overpayment demand to appeal the decision and sixty (60) days from the redetermination decision to make a timely appeal.

The ultimate responsibility for correct coding lies with teh practitioner.  The number one reason for claim denial is lack of medical necessity.  Seventy-two percent (72%) of the time, physicians code incorrectly; twenty-eight percent (28%) of the time they undercode.  Judging by those numbers, accurate coding is done, in the best scenario, twenty-eight (28%) of the time.

For the security of the practitioner, a good rule of thumb is to have an AAPC (American Academy of Procedural Coders) certified coder perform a "snapshot audit" of chart documentation and coding at least one time per year.  This type of audit should follow the "never look back" rule and focus solely on the previous day's charts - not yet filed with the insurance companies.  The AAPC certified coder should either be obtained by, or notify, the practitioner's legal representative and the practitioner's accountant of the intent of the audit and sign all necessary NDA's (non disclosure agreements) before commencing the audit.  The audit should include a comprehensive retraining of proper coding and documentation techniques.

 

CMS, ONC Release Meaningful Use Final Rules

July 13, 2010 - CMIO.net

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) issued the final rules on Meaningful Use and Standards and Certification, which providers must follow in order to benefit from the approximate $27.3 billion in financial incentives over 10 years, authorized under the HITECH Act’s EHR incentive program.

Those who joined in the announcement were Kathleen Sebelius, Secretary of the U.S. Department of Health and Human Services, Donald Berwick, MD, new CMS Administrator, David Blumenthal, MD, the National Coordinator for Health IT and Regina Benjamin, MD, MBA, Surgeon General

The department published proposed meaningful use requirements on Jan. 16. The proposal prompted some 2,000 comments. Today, the HHS released a final regulation for the first two years (2011 and 2012) of this multiyear incentive program.

“Electronic health records are the foundation of a high performing and high quality health system,” said Sebelius. “When the record is properly designed and implemented, it is a powerful force for increasing physician and patient satisfaction.  We hope that other provider groups will embrace these standards.” She noted that only 20 percent of hospitals and 10 percent of physicians use basic EHRs.

The centerpiece of the program begins in 2011, when doctors and providers can receive incentives for the use of IT. “In order to receive these incentives, providers will need to embody these standards, as it was never our goal to use technology for technology’s sake,” Sebelius said.

Likewise, Blumenthal wrote in an editorial that was simultaneously released in the New England Journal of Medicine: “HITECH’s goal is not adoption alone but ‘meaningful use’ of EHRs—that is, their use by providers to achieve significant improvements in care. The legislation ties payments specifically to the achievement of advances in healthcare processes and outcomes.”

The final regulation is divided into two groups: a set of core objectives that constitute a starting point for meaningful use of EHRs and a separate menu of additional important activities from which providers will choose several to implement in the first two years, Blumenthal explained.

   

CMS to Integrate Quality Reporting Programs

June 28, 2010 - Mary Mosquera, Government Health IT

The Centers for Medicare and Medicaid Services (CMS) plans to combine data on healthcare quality required by the health IT meaningful use plan into its ongoing physician quality reporting and incentive program.  The new health reform law required CMS to integrate its Physician Quality Reporting Initiative (PQRI) with data from the HITECH Act's meaningful use provisions by Jan. 1, 2012.

Under the PQRI, physicians who participate in Medicare can receive incentives for reporting various quality measures, a select number of which are aimed at those who want to report using EHRs.  Providers who become meaningful users of EHRs, as laid down by the HITECH Act will also be eligible for incentive payments. A final rule on that is expected soon.

The CMS has requested public comment on how it should integrate the two programs, included within a proposed rule about changes in Medicare physician payments for 2011. CMS expects to publish the proposed rule July 13.  “In an effort to align PQRI with the EHR incentive program, we propose to include many ARRA core clinical quality measures in the PQRI program, to demonstrate meaningful use of EHR and quality of care furnished to individuals,” the proposed rule says.

Meaningful use measures that physicians could use for PQRI reporting through electronic health records include such things as blood pressure measurement for hypertension, body mass index screening and prevention care follow up, and drugs to be avoided in the elderly, the CMS says. 

   

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