Last Friday, CMS posted an update to its RAC website. This update is in response to questions CMS has been receiving regarding the timing of RAC reviews. Many providers have asked CMS when will they be "eligible" for RAC reviews. CMS has clarified that RAC reviews are not being phased in by provider type, but by review type. In other words, automated reviews, then complex reviews, then medical necessity reviews.
As a helpful guide, CMS has published a document that outlines this phase in strategy. The guide is divided into two columns, reflecting the phase-in map's color coding. Yellow states and green states (which were originally scheduled for March 1, 2009 phase-in) are on the earlier schedule. Blue States (which were originally scheduled for August 1, 2009 phase -in) are on a later schedule.
A key point made by CMS is that no reviews will occur in a state until provider outreach has occurred in that state. CMS also notes that before any reviews take place they must have been approved by CMS and posted to the RAC website. CMS expects the first such postings to take place in July 2009.
Home health and hospice providers in the yellow states should start checking for RAC outreaches in their states. (You can find a schedule here.) You should also be checking your RAC's website for posted reviews. Once you see those, you will know that the automated reviews have begun and that other reviews will be coming on-line as scheduled. If you are in a blue state, you should start checking your RAC's website in August. (Just go ahead and put it on the calendar. You will be glad you did.)
If you have not started preparing for the RAC's, now is as good a time as any. I have touched on that topic here, and there are many other resources available. Some key points that are worth repeating, audit claims now to identify errors. You can determine specific errors to look for by looking at your history of claims and past errors you have made as well as by looking at guidance documents from CMS and OIG. Auditing and monitoring will play a big role in preparing for RACs.
You should also consider employee training and making sure you have procedures in place to respond to document requests and recoupment requests. Responding to document request and/or timely appealing recoupment requests is also very important. You would hate to owe money simply because you responded to slowly.
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