Even though the rollout of the new Medicare Recovery Auditor (RAC) contracts has been continuously delayed by contract award protests, the Centers for Medicare & Medicaid Services (CMS), in an end-of-year move, announced the awarding of the Region 5 Recovery Auditor contract to Connolly, LLC. Region 5 is a region exclusively devoted to the review of DMEPOS (durable medical equipment, prosthetic and orthotic suppliers) suppliers, home health agencies, and hospice providers. Connolly is currently the “old” Region C RAC and was the first RAC to emerge when the permanent program started, posting its first automated issues in June 2009.
For CMS, this is the beginning of a new era, one in which transparency and reduced provider burden have been promised. New improvements to the RAC program are outlined online at Recovery Audit Program Improvements. It is interesting to note that transparency and lessening of provider burden also were cited as intended goals when the permanent program was rolled out, as indicated in a CMS slide presentation released in April 2009. It would appear that CMS is now doubling down on those promises as this new era begins.
While the awarding of the five new RAC contracts was expected last spring, delays were encountered due to pre-award protests involving Regions 1, 2, and 4, and a lawsuit in the U.S. Court of Federal Claims by CGI Federal. CMS expects the process to continue through late summer of this year. Last August, CMS announced the initiation of contractor modification to the “current” RAC A, B, C, and D contractors to allow for the restart of limited reviews. The restart reviews have largely been automated reviews, but a limited number of topics were announced by CMS for complex medical review (Monitor Monday listeners have responded in our weekly polls that the “limited restart” automated and complex reviews are underway).
By early November 2014, CMS indicated that the procurement process was continuing for Region 3 (Part A/Part B claim reviews for Florida, Tennessee, Alabama, Georgia, West Virginia, Virginia, North Carolina, and South Carolina), as well as for Region 5. Industry experts were mixed on whether CMS would award Region 3 and Region 5 prior to the resolution of the pre-award protests, but this has been partially answered with the awarding of Region 5.
So what is in store for DMEPOS, home health agencies, and hospice care? Although the existing RACs have focused largely on hospitals, reviews are not entirely new to such providers. But now with Connolly, an experienced RAC contractor, providers should expect a process involving automated reviews as well as complex medical reviews. This new national RAC will not be distracted by hospital or physician issues, and will likely focus on known areas of vulnerability as reported by the Medicare Administrative Contractors (MACs), the Office of Inspector General (OIG), the Zone Program Integrity Contractors (ZPIC), as well as the findings from the Comprehensive Error Rate Testing Program (CERT).
Here are five tips for getting ready for the Region 5 National DMEPOS/HH/Hospice RAC:
- Sign up at the Connolly provider portal and familiarize yourself with its website.
- Review your MAC’s website for probe reviews and CERT reports; put their findings and recommendations on your monitoring and auditing work plan.
- Review published OIG reports and similarly audit facility charts as if the OIG were on site.
- Scrapbook your way to success early in the process and be prepared by knowing your MACs’ local coverage determinations (LCD) and applicable timelines.
- Sign up and tune in to Monitor Monday broadcasts, the original source for all things RAC and now going on seven years of live broadcasts/podcasts with Chuck Buck, Nancy Beckley, and other featured industry expert panelists.
About the Author
Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practice. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Monday where she serves as a senior national correspondent.
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