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nbeckleyFall is a great time of year.

If you live in Florida, you finally can open up your windows for some fresh air. If you live in New England, you are basking in the beauty of the changing leaves. If you live in the mountains, you are hoping for an early snowfall.

However you may be enjoying “waiting,” though, the clock is ticking down toward the full implementation of the Recovery Audit Contractor process. While automated reviews are purportedly underway, there has not been much reported by those receiving the first denial letters and recoupment demands of the process.

What is happening?

It all seems too quiet, doesn’t it? All of the RAC pundits (such as myself) are waiting to hear from providers about the denials. How many denials are you receiving? What percentage of overall claims is that figure? Who did pre-audits on predicted topics and thus were able to prevent a RAC review of the claims? Who did audits on the approved topics and found issues that required self-reporting and refunding?

It seems we all will have to wait a bit to dig into these topics and begin to fully analyze not only these issues, but the different approaches that each of the four recovery audit contractors are taking. Will their approaches be as different as their Web sites?

No Sense of Urgency?

I was on a conference call the other day with a number of healthcare professionals belonging to advisory committees concerning Medicare. An agenda item mentioned the RAC program’s pending implementation along with approved topics for automated reviews.  One member of a committee asked where she could get information regarding the RAC program, as she had heard about it and wanted to provide her facility with more information. Is this even possible? Are providers just now hearing about the RAC program and wondering how to get information?  Actually, for many providers, there is just no sense of urgency. But how could this be?

The demonstration program started on both coasts (in Florida and New York in the East and California in the West). There is a whole lot of country in between, and those providers who are on top of things have been following the topics that ignited much of the controversy surrounding the RAC demonstration.

For example, the inpatient rehab community has left no stone unturned in advising its constituency about the havoc that the demonstration project wreaked in California. I just spoke with one California rehab director who is completing her final few successful appeals on a massive amount of rehab denials, and she exclaimed, “I am getting all my money back!” Two years and tens of thousands of dollars later!

Passing the Buck

Maybe some of the topics don’t look too threatening to your facility; maybe the clinical folks who are responsible for documentation to support medical necessity feel that this is a finance problem and finance will handle it. Maybe finance thinks that quality assurance or medical records will manage RAC requests. And maybe internal audit has been assigned to handle compliance and it feels that risk management should be handling RAC problems.  After all, there just does not seem to be too much of a threat looming – or does there?

This is a great time to re-assess RAC risks for your facility or practice:  the OIG just released the 2010 Work Plan, representing 128 pages of opportunity to analyze topics that present potential problems for your facility. Check your intermediary or carrier’s Web site for the latest CERT error rates, review the OIG audit reports, examine all the current CMS-approved issues for automated review, conduct your own automated reviews, and don’t forget your “commonplace book.”

Then, by the end of the month, say on Friday, Oct. 30, it will be a great day not to trick, but to treat your staff and departments to some Halloween fun.  It’s a great excuse to put on a costume, gather a huge bag of candy, and “treat” every department and staff member to some sweets to go along with some RAC information and support. If you really get the fever, make it a full-blown Friday evening RAC event and cover all the shifts.

Let me know what time you’ll swing by my department, and BTW – make it Reese’s Peanut Butter Bites!

About the Author

Nancy Beckley is a co-founder and president of Bloomingdale Consulting Group, Inc., providing consulting services to the rehab professional. Nancy is certified in healthcare compliance by the Healthcare Compliance Board, and serves on the Part A and Part B Provider Outreach Education and Advisory Panel for First Coast Services Options (Florida Medicare). She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities.

Contact the Author



Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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