Recovery Audit Contractor (RAC) Program Underway
The Recovery Audit Contractor (RAC) program is under way, and outpatient rehabilitation and CORF/OPT services are now subject to review. The program, a wide-ranging cost-containment plan, is expected to cut improper payments in Medicare programs and identify ways to diminish or eliminate altogether any future improper payments, which may include payments for services that are not covered, coded improperly, or duplicate charges. The Centers for Medicare and Medicaid Services (CMS) plan to expand the program to all 50 states over time (visit www.cms.hhs.gov/RAC to view the schedule).
Outpatient rehab is within the first set of CMS-approved audit issues. The speech evaluation code, and physical therapy and occupational therapy evaluation codes, can only be billed as a unit of “1.” In the section on Timed and Untimed Codes, CMS provides numerous examples of appropriate billing methods.
Provider outreach must occur within a state before any reviews can take place. Connolly Healthcare, which is contracted to perform recovery audit services in Region C, is the first of the four contractors to hold the mandated town hall meetings (visit this site for more information: www.connollyhealthcare.com/RAC/pages/cms_RAC_Program.aspx).
To prepare for a review, physical and occupational therapists should conclude whether they have billed evaluation and/or service-based codes erroneously. If their internal audit finds billing errors, they need to find, via their compliance program, the procedure for making a voluntary refund or perhaps a self-disclosure. Those who feel they may have difficulties may wish to perform the audit through attorney-client privilege.
For more information, visit the Web sites for the RAC jurisdictions, as follows: Region A: Diversified Collection Services (www.dcsrac.com), Region B: CGI (http://racb.cgi.com), Region C: Connolly Consulting Inc (www.connollyhealthcare.com/RAC), and Region D: HealthDataInsights Inc (no Web site yet; racinfo@emailhdi.com).
Source (verbatim): Rehab Management’s RehabToday enewsletter dated 08/27/09
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