The second part includes a notification letter sent to the provider explaining the potential billing error and giving the provider 45 days to submit documentation to support the original billing, according to CMS. This is the same timeframe given to providers to submit documentation for a claim that has been selected for complex review.
As a whole, "semi-automated" reviews may lead to additional burdens for providers, according to Elizabeth Lamkin, MHA, partner/CEO at Pace Healthcare Consulting, LLC, in Hilton Head Island, SC.
"We've known all along that automated reviews could turn into a complex review, and now they've added a formalized process," she says. "This really emphasizes the risks of automated reviews because the RACs can scan unknown numbers of records for issues to be used for "mining vulnerabilities."
She continued, "These could then become complex reviews and be used for identifying issues for extrapolation. This could be the tip of the iceberg as contractors become more sophisticated."
James Carroll is associate editor for HCPro's Revenue Cycle Institute.