"CMS stated they will share the data with the RACs for possible review of post-audit period claims moving forward to ensure their edits are working properly," she says. "But if this sampling period is not managed by the RACs, will CMS recoup identified overpayments prior to completing the appeals process?"
In addition, providers should consider the fact that there appears to be no record pull limitations or recoupment guidelines as is mandated for the RACs in the permanent program. Providers should keep these factors in mind going forward, according to Twist.
"IRF facilities need to consider these matters when planning for their post-payment appeal processes," she says. "In preparation, they should also ensure that they are compliant with the transfer regulations outlined by CMS to avoid future issues."