As
of January 1, 2012. Recovery Audit Contractors (RACs) will be abble to examine
claims before they are paid. CMS states that
these 'prepayment audits' will be conducted on certain types of claims that
historically result in high rates of improper payments.” Want to know what
those claims are? So do we. Because these claims have not been defined,
everything is fair game. The program will begin in areas with high populations
of fraud- and error-prone providers. These states include California, Florida,
Illinois, Louisiana, Michigan, New York. The pre-payment reviews will also be
conducted in “high claims volume states including Missouri, North Carolina,
Ohio,and Pennsylvania. Pre-payment review
threatens PTs because it significantly impacts cash flow. Sadly, there are no
substantive criteria or procedures in place to determine placement on or removal
from pre-payment review. Because RACs are finically incentivized, and the
harsh impacts that pre-payment review can have on providers, we continue to
forewarn you of the potential hazards of improper documentation and
billing.
As stated many times in this blog, Medicare's goal is to reduce
overpayment, fraud, and abuse. By CMS' outsourcing to RACs and providing them
will the most motivating of incentives (financial gain) the RACs have
been successful. The RAC reimbursement incentive is they receive a percentage
of the refund obtained from the medical provider. As also stated many times in
this blog, please employ MediGraph properly to prevent becoming an audit
victim. Documentation of impairments (ROM loss, strength loss, pain, etc.)
alone will not satisfy the 'Medically necessary' requirements for CMS and the
RACs. Satisfying medically necessary is where the RACs have been most
successful. You must employ the functional testing components and outcome
questionnaires built into MediGraph to overcome the RACs. For more info, the
link to CMS is below. As always, if I can help, please
call.
Regards,
Tom Kane, PT
https://www.cms.gov/apps/media/press/factsheet.asp?Counter=4170&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=&cboOrder=date
s.