Let's Discuss the RAC Discussion Period

But providers shouldn't wait until day 39 or 40 to contact their RAC. "CMS was very careful to say to providers that they should contact their RAC as soon as possible during the discussion period because it doesn't stop the recoupment," Cohen says. "But if the provider can quickly convince the RAC that an error was made in denying the claim during the discussion period, and the demand/remittance step isn't initiated, there may be the opportunity to stop the process."

To effectively and efficiently take advantage of the RAC discussion period, Cohen recommends providers do the following:

Group similar denials whenever possible. Use your tracking database to group issues and then talk about them globally. "That way, when you talk to your RAC, instead of having 200 issues to discuss, you have 10. You'll probably be a lot more successful."

Stay organized. Especially when it comes to complex reviews, organization is critical. Use tracking databases or spreadsheets to document and track denials. They will help you keep on top of deadlines and recognize commonalities between denials that may help identify whether a claim is defensible during the discussion period or appeals process, or when you need to correct an error.

Use strategy. "You'll only want to go to the RAC during the discussion period for those claims you really feel like you want to defend," says Cohen. "I'd avoid calling them with 50 claims and asking the RAC to go through each one to explain why they denied it. I'm not sure you want to spend that much time, much less the RAC."

Don't get sidetracked. Providers should use the discussion period, but shouldn't let it distract them from determining whether they want to appeal the claim, or given the early deadlines they need to meet, if they want to stop recoupment (e.g., they can appeal by day 30). There are many decisions providers need to make, Cohen says. So it is important that they don't let the discussion period distract them too much from everything else that needs to be done.