Late yesterday, February 18, 2014, CMS announced several changes to the RAC
program as they engage 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: The last day a recovery auditor may send postpayment Additional
Documentation Requests (ADR)
February 28: The last day a MAC may send prepayment ADRs for the Recovery
Auditor Prepayment Review Demonstration.
June 1: 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, but 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.
1) Recovery Auditor’s 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.
2) Recovery Auditor’s will be required to confirm with provider receipt of a
discussion request within three days.
3) Recovery Auditors will be required to wait until the second level of
appeal is exhausted before they receive their contingency fee.
4) CMS will establish new and revised ADR limits that will be diversified
across different claim types (e.g., inpatient, outpatient).
5) 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 will continue to keep you informed as developments occur!
Please visit our website at: www.naaop.org
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