A recent article from the American
Hospital Association (AHA) discussed the costs associated with appealing a RAC
audit. The AHA paper is quite revealing of how the RACs posses numerous
advantages in extracting a refund from you (the only way a RAC get paid for
their efforts). One of these advantages is that a RAC appeal costs
between $2,000 and $7,000 dollars per claim (per individual patient audited).
The cost- benefits ratio of a RAC appeal becomes decidely less attractive for PT
appeals because of the costs. Why? If a RAC requests a $1,000 refund, would
you be willing to spend between $2,000 to $7,000 to protest this refund?
Probably not. Do not misinterpret my position. I understand the arguments
based on principle when a person believes thay are being penalized unjustly.
But from a business perspective, the decision to spend between $2,000 - $7,000
to prevent the RAC from capturing $1,000 is a losing proposition.
Regrettably, I must state that the RACs are not auditing records that are free
from errors. Frankly, RACs do not have to fabricate their findings to obtain a
refund. Medical providers are creating plenty of opportunities for RACS. When
codes are not supported by proper documentation the RACs are emboldened. There
are limits to the RACs'''' authority, but these limits are primarily window
dressing. RACs are limited by the number of charts they can request per 45 day
period. For example a therapy practice with five or less therapist is limited
to auditing 10 charts every 45 days. However, that 45 day period can be
extended indefinitely. Stated plainly, every 45 days the RAC auditor can
request another 10 charts. Unfortunately, the RACs can go back three years from
the date of the audit and continuously request records.
I implore my colleagues to pay attention to these warnings. I will not repeat
what we must do to prevent RAC audits. Those suggestions have been presented on
numerous occasions on this blog. Consider this strategic view; if a RAC
reviews the claims you are now submitting, and your coding and documentation
meet the current standards, the RACs are unlikely to request a 'Complex'
review. Avoiding a 'Complex' helps to deter the RAC from reviewing your
previous records because the RAC prefers to look for someone that has current
documentation deficiencies. Obviously, a person whose recent charts have
deficiencies is more likely to have past discrepencies as well, which presents
the RAC with the opportunity of capturing additional revenue from the fees that
you were paid in the past. Do not make yourself an easy target. Use the
MediGraph tools at your
disposal to avoid the RAC trap.
Tom Kane, PT