- Determine what you are going to review. The timeline is short for appealing unfavorable findings, so reviewing all the records before the request may not be possible, says McManis. "Review the data that is already out there," she says. "Identify where your facility may be an outlier for areas that are considered at risk, such as chest pain, stroke, one-day stays, and so on."
- Use the discussion period. This period of time was implemented by CMS as a way for providers to have an open discussion about how a RAC may have made a determination, and allows the provider to offer additional information, according to Debbie Mackaman RHIA, CHCO, regulatory specialist for HCPro, Inc. "This is a valuable resource for providers looking to avoid the appeals process," she says.
- Know how and when to appeal RAC determinations. A facility's RAC team should determine which charts contain documentation to support the appeal, according to Mackaman. "This requires expertise from all areas of your team," she says. "In addition, request the credentials of the HDI review staff, and request to talk to the contractor medical director, when appropriate."
- Develop a letter template. Use the letter—which should contain the complete information needed—at every level of appeal for consistency, and provide explicit detail to support your position, according to Mackaman. "Be sure to include the judgment of the admitting physician and a letter supporting medical necessity," she says. "This will also help with keeping inside the timelines, which need to be monitored. If a deadline is missed, your appeal is finished!"
- Develop a tracking tool. This tool, which should track all aspects of the RAC process from additional documentation requests to the resolution, needs to cover the who, what, where, when of a decision, according to Mackaman. "Pay attention to the details here, and don't just count on your memory!" she says. "There is no such thing as being over-preparedness when it comes to the RAC process."
Debbie Mackaman RHIA, CHCO, and Jennifer McManis, RHIT are speaking in the September 21, 2010 audio conference: RAC Audits in Region D: Strategies for success under HDI.
James Carroll is associate editor for the HCPro Revenue Cycle Institute