Top leaders need to provide direction to create an effective approach to RACs.
Whether your facility has received a request for medical records from a recovery audit contractor yet, those requests are coming, as the program is fully rolled out in 2010. Leaders are not only often flummoxed about how much of their revenue is at risk from RAC reviews, but they’re also confused about their role in how their hospital or physician practice responds to patient record requests.
In forming a strategy to protect your facility’s interests, collaborative procedures need to be implemented among a variety of departments that haven’t necessarily worked together often in the past, including the central business office, patient accounting, corporate compliance, internal audit, and finance and reimbursement specialists, among others, says Stanley Padfield, director of health information management at Lee Memorial Health System in Fort Myers, FL.
Padfield designed a program not only to track RAC requests, but also to remediate endemic communication problems between departments that document medical necessity coding and other essential processes needed for the proper Medicare reimbursement on which the RACs focus.
Lee Memorial gained experience in a RAC demonstration project.
"We were getting requests for 400-500 records at a time," he says, noting that it took five FTEs dedicated to RAC audits to comply with requests. "The new rollout limits the number of charts based upon your volume and tightened the time requirements on the RAC side," he says.
Still, dealing with RACs can be quite daunting not only for the rank-and-file but also for leaders in charge of making sure the RACs won’t have a devastating effect on revenues.
"This has to start with the CEO and the board," says William Malm, ND, RN, who is a healthcare consultant with Craneware, with U.S. headquarters in Orlando, FL.
"Speak directly to the employees to let them know this is a priority," he says.
"Hospitals are focused on the hurdles RACs represent, but there are positive benefits," Malm says. "The work preparing also provides opportunity for improving financial performance and clinical care because people are documenting and communicating better."
Hospitals will have to gear up for an initial surge of requests.
Based on their Medicare population, they could be looking at anywhere from 100 records a month to 200 every 45 days. Preparing those records takes a lot of manpower.
Padfield used a vendor called HealthPort to help copy, box, ship, and monitor patient records, as well as provide assistance on appeals.
"The same fear existed when DRGs came around," says Malm. "Fear existed when I lived through compliance and OPPS implementation. This is another aspect they just need to prepare for."