Avoid RAC Threat by Understanding Extrapolation Process

If a facility has reason to believe it may have a high error rate with a particular RAC issue, it could complete its own extrapolation process, according to Mackaman.

"If the RAC performs an extrapolation and it is inconsistent with the facility's internal audit, an appeal could be considered," says Mackaman. "But keep in mind that if the internal audit is not in favor of the facility, the provider should consider what the next steps are regarding self-disclosure."

On top of running these reviews, facilities also reserve the right to appeal. Providers can: choose to appeal the methodology used in the findings; the sample section (overpayment amount) itself; the initial justification of performing the extrapolation; and the application of the findings, Mackaman says. Although RAC extrapolation is a complex process, facilities can still defend against it.

Overall, preparing for success against potential RAC extrapolation would be the same as preparing for RAC audits in general, she adds. Understanding the issues and performing your own internal audits to identify your potential error rates; keeping current with ongoing RAC activity; implementing a RAC team; and running concurrent reviews are some of the main aspects of diligent preparation against RAC audits that, in turn, will help defend against RAC extrapolation.