As Bob Dylan sang in the early 1960s, “The times, they are a’ changin’.” If he were to recompose that song in 2013, he might write “the boundaries, they are a’ changing,’” alluding to Medicare’s Fee for Service Auditor Recovery Program.
The new boundaries for CMS’s Recovery Audit Contractor (RAC) four regions are expected to go into effect in late 2013 or in early 2014. A sneak peek of the new RAC region map is available on the CMS website. RACs will continue to work with the existing regions through November 15; they’ll respond with results until January 15, 2014.
The new territories were designed to reduce audit management disruption, especially for organizations with facilities in multiple states. Though disruptions will be minimized, a variety of key operational and workflow modifications will be needed to accommodate the changes.
The new RAC regions--Northeast, Southeast, Midwest and West--should dramatically simplify the audit process since they are designed in a more consistent, regional manner. (Please note that Pennsylvania, New Jersey, Maryland and Delaware will be served by the Western Region RAC.) Fewer RACs will be involved, and audit management and reporting should become more straightforward.
To get started, get acquainted with the new RAC region map. Then adjust team assignments, software databases and executive reporting dashboards to reflect new RAC assignments. Once that’s accomplished, solidify plans to communicate with your new RACS and to educate your staff.
Communicate and Educate
Take the following steps as to assist while preparing to meet your new RACS:
Ask your existing RAC if your contact information will be transferred. If not, quickly share all contact information with your incoming contractor. Remember, faulty addresses and contacts continue to be a chief complaint of the RAC program and may lead to unwarranted technical denials.
- Conduct educational sessions for all staff involved in the RAC request process and audit management, including your release of information (ROI) staff or outsourced vendor. Also ask your new RAC if any education will be provided.
- Request samples of the incoming contractor’s request letters and other correspondence to familiarize everyone with the new request and response paperwork formats.
Old Cases are Still Appealing
So what becomes of the RAC denials and audit appeals already in progress? Whichever RAC originally issued the denial follows that denial through the entire appeal process, even if the provider’s RAC region changes. Organizations should prepare to manage a large number of “in process” cases. These cases must be separated out, carefully tracked and closely monitored for several reasons:
Block any inadvertent duplication by the new RAC.
- Measure the correct appeal success and activity by RAC auditor and case type.
- Know denial rates by old RAC versus new RAC and by case type.
- Calculate the financial impact of RAC regional transition.
- Calculate the operational costs of RAC regional transition.
Expect delays in workflow between RAC reply periods during the transition. The normal process of communicating audit results and sending demand letters may also be temporarily interrupted. Documenting the old RAC and future new RAC for each case is a must. Best practice is to document every aspect of every audit during the transition period.
After five years, we’re well acquainted with the RAC program. We know the typical audit patterns, we’ve learned important management lessons, and we’ve devised successful appeal strategies. Yet transitioning to new RAC regions will be a bit of a challenge. It’s critical to continue capturing data and tracking audits throughout the transition. You’ll mitigate current RAC risk and garner valuable business intelligence for tomorrow.