Since the beginning of the permanent Recovery Audit Contractor program, the four RACcontractors have been mandated to perform provider outreach to “notify provider communities of the recovery auditor’s purpose and direction,” according to the RAC Statement of Work (SOW), which was updated in September.
The SOW details how the RACs submit a baseline provider outreach plan to CMS. CMS uses the plan as a starting point for discussion, which presumably would lead to a more detailed plan that should include “potential outreach efforts to associations, providers, Medicare contractors and any other applicable Medicare stakeholders.”
On a hunch (the hunch being that provider outreach has come to a grinding halt), I decided to look into the efforts of the contractors in this area. As of this writing, I still am awaiting a definitive answer from DCS, the Region A RAC, and Connolly, the Region C RAC. The reason for this is that, unlike their counterparts in Regions B and D, DCS and Connolly do not list their past or future outreach sessions on their websites. It would seem, from all current appearances, that my hunch is correct.
CGI, the Region B RAC, does have its schedule of all conducted outreach sessions on its dedicated RAC website. The last provider outreach session held by CGI occurred on March 24 of this year in Illinois. Being from Wisconsin, I was interested in particular by the fact that in my state, only three such sessions have ever taken place. To add insult to the injury of ignorance, none of these sessions was aimed directly at facilities or physicians.
HDI, the Region D RAC, doesn’t make its list of outreach meetings easy to find, but after some fancy clicking of links I came across this page on its website. As it indicates, the last outreach session for Region D providers occurred in September 2009.
To get a mental picture of what this outreach vacuum means for the provider community, it helps to compare the schedules of these two contractors with the number of approved issues added by each RAC during this same period when outreach education didn’t occur. In Region D, 336 of 386 approved issues have been added since HDI’s last provider outreach session was held. In Region B, 53 new issues have been added since March 24, with 43 of these issues being complex.
RACs and the SOW
While many larger organizations have taken to discussing RAC issues on their own as groups in search of enlightenment, it would appear that the RACs are violating their work order. In the SOW, the RACs are tasked with submitting monthly progress reports to CMS outlining all work accomplished during the previous month. These reports are supposed to include details about upcoming provider outreach efforts, but perhaps CMS is so busy dissecting some appalling appeal statistics that they have been skimming over this requirement.
When the RAC in charge of the most densely populated state in the country has produced 87 percent of its approved issues list without presenting outreach to providers in its region, I would argue that this is indicative of a problem.
Hospitals at this point know the ins and outs of the program, but I continue to encounter physician groups across the country that have only passing knowledge of the RAC program. Many that I encounter have no knowledge of RACs at all.
CMS asks a lot from the provider community with regard to compliance. Perhaps the time has arrived for physicians to request that CMS return the favor with a little shared knowledge.
About the Author
Paul Spencer is the Compliance Officer for Fi-Med Management, Inc., a national physician practice financial management company based in Wauwatosa, WI. Paul has over 20 years of experience across all facets of healthcare billing, including 6 years spent with insurance carriers. In his current role with Fi-Med, he acts as a physician educator on issues related to E/M level of service and documentation audits by CMS and other outside entities. Paul has carried the CPC and CPC-H credentials from the American Academy of Professional Coders since 1998.
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