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My first suggestion would be to perform a brief internal and external review of the subject matter. He goes on, “The RACs are coming and we know from the recently completed Demonstration Project that the majority of overpayments identified -somewhere between 70% – 75% – depending upon which statistics you review were from coding errors and lack of documentation to support medical necessity. Thus it would be logical to focus your attention and resources on these areas.”

Look to Duane Abbey, Ph.D., CFP, to explain extrapolation and its RAC implications. Says Abbey in Today’s edition, “significant overpayment amounts may be claimed based upon the extrapolation process using a relatively small audit sample.” And he warns, “the manipulation of variables in choosing sample sizes can be critical within the overall context of the issue being addressed.”

Talk about the need for knowledge transfer – Patricia Dear cautions readers to be aware of Transfer DRGs, saying these are easy targets for RACs. Dear cites the case of a facility that was hit with a $2 million recoupment bill due to…incorrect discharge dispositions.

And wrapping up Today’s edition, Cheryl Servais, MPH, RHIA, describes the documentation imperative. “The RAC will request medical records from a provider in order to determine if a payment error has occurred in those situations where incorrect reimbursement is suspected. The provider has 45 calendar days from the date of the request to provide the copies of the medical records. If all of the requested information is not provided, the RAC has no documentation to support the claim and the payments made to the provider. When this occurs, the RAC will issue a demand letter for recoupment from the provider of all or part of the reimbursement.” As she says, there’s an old adage that says, “if it isn’t documented, it didn’t happen.”

You’ll find all this and more in Today’s edition of racmonitor.com – the single most important source for RAC news and information.


Chuck Buck

Chuck Buck is the publisher of RACmonitor and is the program host and executive producer of Monitor Monday.

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