CMS Moves Permanent RAC Process Forward

Andrea Kraynak , April 15, 2009

CMS continued its efforts this week to educate healthcare providers on the permanent Recovery Audit Contractor program with an Open Door Forum call for Medicare Part B providers on April 14. A similar call for Part A providers was held on April 8.

Providers may wish to listen to the Open Door Forum calls, including the helpful Q&A portion of the program—even those who feel as though they are experts on the RAC program may find they learn new information. For instance, consider the following points discussed during the April 14 call:

On medical record request limits: If your medical record request limit is per National Provider Identifier, listen up. The record request limit is based on your group NPIs, not the number of NPIs assigned to your individual physicians. "This could be an issue," explains Nancy Beckley, MS, MBA, CHC, of Certified Healthcare Compliance at Bloomingdale Consulting Group, Inc., in Brandon, FL. "An 18-member physician practice group that has a group NPI could expect requests of 50 medical records every 45 days, whereas if this same medical group issues a different group NPI to each of its three practice locations (each of which have six doctors), the physician practice group could have up to 30 medical records requested for each of the three groups—for a total of 90 medical records every 45 days."

On line-item billing: For a claim containing multiple CPT codes for the same date of service, each code (i.e., procedure) constitutes an item that RACs can review. Beckley believes this may come as a surprise to many providers considering a visit (which could encompass several CPT codes) as a claim for a date of service.

On contingency fees: RACs receive the same contingency fee regardless of whether they identify overpayments or underpayments.

On submitting electronic claims: The RACs currently aren't set up to receive electronic data interchange—nor will they be for some time. For now, submit paper claims (via fax) or send images of electronic medical records via CD or DVD.

Recordings of both calls will soon be available on the CMS Open Door Forum Web site.

If you prefer to find out more about the RAC program during a live outreach session, you may find CMS is hosting an educational session in your neck of the woods. CMS is partnering with state hospital associations, state medical societies, and CMS regional offices to roll out these meetings. Check out CMS' recently updated RAC education and outreach schedule for information on available sessions. The schedule also contains information regarding which types of healthcare provider (e.g., hospitals, physicians, skilled nursing facilities, etc.) should attend the various sessions, as well as who will provide the presentations during the sessions. CMS will continue to update the RAC schedule as new sessions become available. (View the most recent version on the CMS Web site.)

If you are in a blue state, you will start seeing outreach sessions in your area beginning in August. If you are a yellow or green state, you should see sessions in your area soon. If you are a yellow or green state and believe CMS has no outreach sessions applicable to your organization in your area, e-mail CMS.

CMS acknowledged during the April 14 RAC Open Door Forum call's Q&A portion that hospital associations and medical societies hosting the provider outreach sessions may have limited participation to "members only," leaving nonhospital or nonphysician providers (e.g., physical therapy clinics or DME providers) without an opportunity to attend a session, says Beckley. If you find this to be the case, in addition to e-mailing CMS with your concerns, you should also consider contacting your national trade organization. Express your concerns to organizations such as the American Physical Therapy Association, the National Association of Rehab Providers and Agencies, or the National Association for Homecare and Hospice, Beckley suggests.

CMS also plans to provide an outreach presentation on its Web site for providers unable to attend the live sessions.

Andrea Kraynak, CPC-A, is managing editor of The RAC Report, the Coding Educator, and for the Revenue Cycle Institute. She may be reached at


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