In the first of four scheduled nationwide RAC calls, CMS began the first portion with a basic summary of the RAC operational process. CMS representatives began this portion describing how the success of the demonstration led to the implementation of the permanent program, and eventually led into up-to-date concerns such as additional documentation limits, the N432 code, and RAC impacts on critical access hospitals.
Donna Wilson, RHIA, CCS, senior director, Compliance Concepts, has been involved in RACs on every level — having had firsthand experience in the demonstration project up until her most recent previous role as Revenue Integrity Manager in charge of RAC coordination at a large acute care facility. According to Wilson, the best part of these RAC calls are the question and answer periods.
"I believe many providers will choose to opt out due to the title of RAC 101," says Wilson. "However, I suggest that they take the time to listen to the next call; they may learn quite a bit from the great questions."
Many of the questions included in the question and answer period revolved around the N432 code. The N432 code is a RAC denial code that appears on the remittance advice, which is a notice of payments and adjustments sent to providers, billers and suppliers.
After a claim has been received and processed, a Medicare contractor produces the RA, which may serve as a companion to a claim payment (or payments) or as an explanation when there is no payment. During the question and answer period, it was determined that this code should match the date on the demand letter.
In addition, a CMS representative clarified that in the current statement of work there is no timeframe between the discussion period and the issuance of the demand letter, as CMS states that the RAC discussion period begins with the time that either the demand letter (automated reviews) or review results letter (complex reviews) is received through the time recoupment occurs.
For many providers the RAC overview ultimately wasn’t necessary; but the question and answer portion certainly helped address some confusion as well as alert CMS to areas of potential concern in the future.
"Keep in mind CMS continues to stress that the open door forums are not official guidance, but listening in for the questions can be priceless for a provider," says Wilson.