So, what is the next step for providers when it comes to preparation for Medicaid RACs? According to Zebrowitz, the answer is two-fold:
1. Create a rigorous Medicaid admission review process. "Recognize that the rules may be different compared to Medicare and familiarize yourself with the specific differences," he says. "Next, you've got to come up with a way to manage the process concurrently and to ensure you are arriving at a compliant admission status up front, and manage retrospectively to ensure your protection of rights within the potentially lengthy appeals process."
2. Be aware of updates from CMS and the eventual Medicaid RAC contractors, Wheeler adds. "There is likely going to be much more legwork on the Medicaid RAC side if there are multiple contractors that the providers will need to monitor, similar to how providers currently monitor the four RAC sites to stay current on developing issues," she says.
And as always, providers will need to ensure that they have their process in check on the front end, according to Zebrowitz:
"If our experience in the world of Medicare erroneous payment auditing is any indicator, the best defense against inappropriate payment audit denials is having a process to achieve an upfront compliant admission status certification."
View the proposed rule here.