The National Association for the Advancement of Orthotics and Prosthetics (NAAOP) issued the following update on changes to the Recovery Audit Contractor (RAC) program:
On February 18, the Centers for Medicare & Medicaid Services (CMS) announced several changes to the RAC program as CMS engages in the procurement process for the next round of Recovery Audit program contracts. First and foremost, CMS has issued a “pause” in further RAC audits until new RAC contracts are issued. It is not clear when the new RAC contracts will go into effect, but it should be at least several months.
February 21 is the last day a Recovery Auditor may send postpayment Additional Documentation Requests (ADRs).
February 28 is the last day a Medicare Administrative Contractor (MAC) may send prepayment ADRs for the Recovery Auditor Prepayment Review Demonstration.
June 1 is the last day a Recovery Auditor may send improper payment files to the MACs for adjustment.
There are additional changes announced by CMS with which new RAC contractors will be required to comply that may help reduce some of the excessive burdens of the RAC program on providers, as follows. However, none of the announced changes will have a significant impact on O&P physician documentation or the lengthy delays in the Medicare administrative appeals process.
- Recovery Auditors will be required to wait 30 days to allow for a discussion before sending the claim to the MAC for adjustment. Providers will not have to choose between initiating a discussion and an appeal.
- Recovery Auditors will be required to confirm with provider receipt of a discussion request within three days.
- Recovery Auditors will be required to wait until the second level of appeal is exhausted before they receive their contingency fee.
- CMS will establish new and revised ADR limits that will be diversified across different claim types (e.g., inpatient, outpatient).
- CMS will require Recovery Auditors to adjust the ADR limits in accordance with a provider’s denial rate. Providers with low denial rates will have lower ADR limits while providers with high denial rates will have higher ADR limits.
NAAOP said it will continue to keep its members informed as developments on this issue occur.
