Providers may not be taking full advantage of the RAC discussion period, but as review results letters continue to arrive, that could change.
The RAC discussion period begins with the time that either the demand letter (automated reviews) or review results letter (complex reviews) is received through the time recoupment occurs, according to CMS. 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 its determination and allow the provider to provide additional information.
The discussion period is a valuable resource for providers looking to avoid the appeals process, according to Debbie Mackaman RHIA, CHCO, regulatory specialist for HCPro, Inc.
"As a provider, if I receive a review results letter or demand letter, I would want to look at them in a timely manner and then start that discussion period as soon as possible since the clock is ticking," says Mackaman. "If you can provide additional information to support your position and potentially reverse the RAC’s decision, why wouldn’t a provider want to use that period of time?"
Making use of the discussion period may not be something all providers have fully embraced. However, if the RAC’s determination can be reversed during the discussion period, the associated costs are employees’ time to research and discuss, whereas the appeals process can be lengthy and expensive, especially when legal counsel becomes involved. In the end, using the discussion period is a low-risk move that can ultimately pay for itself.
For Carol Kendall, RHIA, RAC coordinator and compliance auditor at High Point Regional Health System in High Point, NC, taking advantage of the discussion period was well worth the effort. "We were able to overturn one DRG change, and saved a CC on another one that will still have a change related to a procedure code; definitely worth the call," she says.
The discussion period is a significant tool for providers to use, but it does have a number of items that need specific attention, in order for a result to be successful, Mackaman says. To start, any facility that is subject to RAC audits should have a RAC team in place. Forming a committee—whether new or existing employees—to deal with the RAC process is an essential part of any facility.
Checking the documentation is the next step, Mackaman says, to make sure all paper and electronic records in a hybrid environment are sent, and that the documentation is consistent.
Also, she suggests pre-reviewing the record prior to receiving the RAC response to save valuable time in anticipation of entering into the discussion period.
"One of the biggest things is timing and tracking, and making sure that as soon as the RAC response is received, you are responding, reviewing, and preparing to enter into that discussion period, when appropriate," says Mackaman.
Ultimately, providers want to properly defend their organizations against RACs and not find themselves with the need for a discussion period. However, in a field of highly detailed, complicated subject matter, perfection is a lofty concept.
The discussion period is essentially an olive branch extended from the RACs to providers that can be used to save money and learn from mistakes. Its purpose is to show the RAC that there is information that would help overturn a decision to recoup funds, and facilities that are not utilizing it or preparing themselves properly may be doing themselves a disservice.
"If facilities don’t have their RAC teams set up to monitor requests and responses in a timely manner, they are going to miss out on that opportunity," says Mackaman. "All providers should be aware of the purpose and the value of the discussion period."