The June report from The Centers for Medicare & Medicaid Services (CMS) has been
released. In the first half of 2011 RAC audits have captured $592. 5 million in
refunds from medical providers. At this pace , RACs will collect $1,850
billion in refunds for 2011. Realisitcally, the $1.850 billion is a low
estimate because RACS are gaining efficiency from their experience. The greater
efficiencies have resulted in a steady increase in refunds. In each quarter
reported, the RACs collect more than the prior quarter. The most problematic
area for providers remains proving medical necessity for
the treatment rendered (
http://www.cms.gov/Recovery-Audit-Program/Downloads/FFSUpdate.pdf).
Throughout the MediGraph
blog and in occasional emails, we have continued to emphasize the importance of
establishing the medical necessity of treatment. We have stressed the
importance of using the impairment model of physical therapy to support the
disablement model. The impairment model (ROM, strength, pain, etc.) will not
stand alone as justification for intervention. The disablement model must
demonstrate that the patient has a functional loss that is verified by objective assessments (functional tests like the 6
Minute Walk, Timed Up and Go, and peer reviewed outcome questionnaires such as
OPTIMAL, Lysholm Knee Index, etc.). All of the tools that you need to prevent
a RAC from picking your pocket are contained in
MediGraph. These procedures
consume time but they are not difficult to perform. If you are not using these
tools, start today. If you need assistance or would like to discuss this
matter, please call.
Regards,
Tom Kane, PT
MediGraph Software