Wednesday, January 7, 2015

CMS RAC Program Updates

Dan Ciolek

During the last weeks of December, the Centers for Medicare and Medicaid Services (CMS) provided two significant updates to the ongoing Recovery Audit Contractor (RAC) procurement saga.

First, On December 24, CMS announced that it was extending the existing contracts for the Part A/B MACs for Region A (Performant Recovery), Region B (CGI Federal Inc.), Region C (Connolly, Inc.), and Region D (HealthDataInsights) through December 31, 2015 for active auditing; and through April 30, 2017 for administrative/reconciliation activities as appeals are processed. This will allow CMS to fulfill its congressional mandate to correct improper payments in an effort to protect the Medicare Trust Funds while the procurement process for new RAC contracts is held up due to a protest at the Court of Federal Claims. In a similar August 2014 notice which extended the existing RAC contracts through December 2014, CMS had announced that “Most reviews will be done on an automated basis, but a limited number will be complex reviews of topics selected by CMS.” CMS has not yet provided clarification whether the RAC scope has changed for this new 2015 contract extension. This is relevant to SNF services on potential increases in Part A PPS claim reviews, and how CMS intends to resume the Part B therapy manual medical review (MMR) program which has been ‘paused’ since March 2014. AHCA continues to monitor and communicate with CMS regarding these issues.

Second, on December 30, 2014 CMS announced that they had awarded the Region 5 Recovery Audit contract to Connolly, LLC. The purpose of this contract will be to support CMS in completing this mission through the identification and correction of improper payments for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), and home health/hospice (HH/H) claims. The Recovery Auditor will review all applicable claims types through the appropriate review methods and work with CMS and the DME and HH/H MACs to adjust claims to recoup overpayments and pay underpayments. This award marks the beginning of the new Recovery Audit contracts and is the start date of the implementation of many improvements to reduce provider burden and increase transparency in the program. A detailed list of these improvements can be found at Recovery Audit Program Improvements. It is important to note that these RAC program improvements only apply to the new Region 5 RAC, and not the Regions A-D RAC contract extensions described above.

CMS has established a Provider Relations Coordinator, Latesha Walker, to improve communication between providers and CMS. Ms. Walker will be working closely with the Division of Recovery Audit Operations and the provider community to address questions and concerns regarding these recent RAC program contact award activities. Additionally, providers should feel free to contact Ms. Walker when issues arise that cannot be solved by discussions with the Recovery Auditor. Ms. Walker may be reached at (410) 786-1101 or Latesha.walker@cms.hhs.gov.

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