RAC Audits Have Arrived

RACs are targeting untimed codes because of what they learned during the demonstration project, says Beckley. For example, RACs found $3.2 million in speech therapy evaluation errors during the demonstration project, and considering these are $200-$400 items, the RACs must have found a lot of errors. Extrapolate this to include physical and occupational therapy services as well, and it's like shooting fish in a barrel, says Beckley.

Mistakes often occur when a therapist enters time codes (for example, one hour in four 15-minute increments) into a hospital billing system, but the system doesn't have the right edit table in place and it incorrectly bills for four time codes instead, explains Beckley.

If your facility uses outpatient therapy codes (e.g., physical and occupational therapy or speech evaluation codes), consider conducting your own internal review. "That way you can correct this issue before RACs get to you," says Beckley. Making voluntary refunds may be your best bet, she says.

Connolly has provided additional information about each of the approved issues on its Web site for providers wanting to learn more about them. For example, for additional information on IV hydration therapy, providers should review the following:

• CMS Pub 100-4, chapter 12, p. 31–32


• CMS Pub 100-20, Transmittal 419, p. 7


• MLN Matters article MM6349, released December 19, 2008, p. 4

Editor's note: For more on RACs, visit the CMS RAC Web site. In addition, RAC outreach and informational events are still going on in many areas. View the latest schedule of events here. Finally, click here for more information from CMS regarding when various types of RAC audits may arrive in your area.