One thing for providers to take note of with this report is the fact that, much like the Audit MICs in this report, Medicaid RACs are also being rolled out with different state guidelines and a lack of a standardized set of rules. According to Elizabeth Lamkin, CEO, Pace Healthcare Consulting, LLC, in Hilton Head, SC., this may provide an early look at what to expect with the Medicaid RACs.
Malm agrees, saying that this report helps to essentially verify that everything that CMS suggested might be a concern in the Medicaid RAC proposed and final rules, is starting to happen now.
"Already before the Medicaid RACs have even started, there is evidence of some of these concerns showing up now," he says. "These concerns include overpayments being slow or nonexistent and leaving it up to the states to determine individual rules."
Now, what exactly does this mean for providers? One immediate need and point of action, when it comes to Medicaid RACs, should involve the training or hiring of an educated care manager, according to Lamkin.
"The government will likely get better and better at auditing—and you can see how aggressive they have been as of late—so hospitals are going to need to get better at front-end documentation," she says. "Providers may also want to have a care manager that is qualifying beneficiaries and documenting admission approvals on the front end that is well-versed in both the state and federal guidelines. I think that’s the only way providers will really be able to attack all of this."