RAC Pre-payment Reviews

I don’t normally touch religion or politics, yet without intent to offend anyone: God protect me from a RAC prepayment review. If you have not had the experience of a RAC review considers yourself lucky. I actually had several potential customers that contacted me due to a RAC review and in most of the cases the result was costly and in some instances followed by closure. RACs targeted 1.1 billion in Medicare payments during the first quarter of 2012, compared to 876 million during the fourth quarter of 2011. CMS recently announced that they will start again in Summer 2012, although no specific date was mentioned. One key factor is that CMS plans to increase the number of reviews from 1.2 million claims to 2.7 million claims. However, that doesn’t mean providers should sit idle while they wait for a firm deadline, Sharon Easterling, CEO of Recovery Analytics in Charlotte, N.C., told HealthLeaders Media. “With the shift of the RAC to up-front documentation review, providers should implement concurrent processes in their case management and utilization review areas,” Easterling said. “Facilities may also want to consider educating their physicians on these particular DRGs to identify key documentation points that help to meet medical necessity.” Medicare Recovery Auditors (RAC) normally review claims before they authorize payment. However, RAC doesn’t have a time limit to review claims. So in some cases I have seen these reviews to last in excess of six months. Furthermore, consider that RAC gets paid based on the money they recover and you can easily put together an scenario where the cash flow to your Practice will slow down to dangerous levels. So in preparation to the worst I will recommend the following: 1. Diversify the Payor source of your Practice as much as possible; 2. Make sure you have access to funds (savings, line of credit, etc.); 3. Develop/Implement a good compliance plan; 4. Make sure your progress notes and records are complete and reflect the services you billed for.