CMS provided a one and a half hour RAC 101 teleconference to hospice and home health providers on May 4th.   It became apparent quite quickly that although the teleconference was provided for hospice and home health, the information presented was generic to all providers.   The slide presentation (click here to view) contained basic RAC information to give an overview of the history and goals of the RAC program as well as how it works.

The most interesting part of the teleconference was the question / answer period which lasted almost a full hour.  During the Q & A it became further apparent that the presenters had not done much (or any) “homework” regarding hospice providers.  For example, they were not aware that HDI, the RAC for Region D has posted two approved issues related to hospice (click here and here regarding these issues).  But it was a good opportunity for providers to ask questions and there were some good ones.

One of the most interesting was a question related to the RAC Validation Contractor.  One of the RAC program’s three keys to success is to “ensure accuracy.”  Part of ensuring RAC accuracy is having a RAC Validation Contractor required to provide annual accuracy scores for each RAC.  The questioner asked whether the Validation Contractor would be waiting until all five levels of appeal had been completed on a denial before determining the annual accuracy score for a RAC.  The answer was no, that the Validation Contractor would be using RAC data from just after the denial determination had been made.  The questioner rightly pointed out that the annual accuracy scores would be suspect since a RAC denial could be overturned on appeal and therefore their initial determination (upon which the accuracy score was based) was in fact inaccurate.  The discussion got increasingly convoluted with the presenter in fact agreeing with the questioner but then saying she was not sure they were on the same page and should take the discussion offline.  It will be important to keep an eye on this because RAC “accuracy” is a huge issue and clearly the Validation Contractor may not be much help to providers in this regard.

Several questions came up regarding how to determine when new issues related to hospice/home health are posted.  Before a RAC can conduct an audit, it must have the subject of the audit - the issue - approved by CMS and the RAC must post it to its web site.  Not all RACs have the same approved issues and not all RACs post their approved issues the same way. For example, only CGI specifies whether or not the approved issue is the subject of an automated or a complex review.  The others do not specify and therefore providers will not know if the audit will include a review of the clinical record (required for complex reviews) or if it is automated with no record review and considered a “slam dunk” by the RAC (although it can be appealed).  The approved issues pages for each RAC are getting very lengthy and as the RACs get rolling into other providers are likely to become even more unwieldy.  A few of the questions concerned how to determine when new issues related  to hospice or home health are posted.  There were not any helpful suggestions provided.  As an  aside,  RAC Assistance for Hospice will alert subscribers when new hospice issues are posted.  We monitor all four RACs frequently.  If you want to monitor yourself, one easy way of doing it is to bookmark the approved issues page for your RAC and periodically do a word search on the page for the term hospice.  At this point, the word is only found on HDI’s approved issues page.

There were some questions related to the coding/educational backgrounds of RAC reviewers.  There is a requirements that coders be certified but no requirements regarding background or training in hospice or home health.  The competence of RAC reviewers continues to be a big concern and it is going to be very important that providers ask for and challenge reviewer credentials if it appears mistakes are being made.

Several people asked questions regarding when hospice/home health can expect to see more RAC activity.  It was clear that even though this call was scheduled and provided,  there is no indication that the RACs are gearing up for increased hospice activity.  This is, of course, subject to change without notice…

This entry was posted on Tuesday, May 4th, 2010 at 4:03 pm by hpwilson and is filed under Prepare, Updates. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.