Getting RAC Ready

A surprisingly high number of respondents said they already had a RAC preparedness program in place (71%). This number may be inflated by providers with heightened awareness of the RAC initiative that may have been more likely to respond to the survey, according to Hoy. Programs generally appear to still be in their early stages. Of respondents with a program in place, 85% started in the past year, and more than 50% started in the past six months.

"As providers begin to receive routine RAC requests, the teams will undoubtedly continue to develop and become more sophisticated," Hoy says.

Nearly half of respondents already have a RAC coordinator in at least a part-time capacity; 40% have a full-time coordinator. Of the respondents who said they don't yet have a RAC coordinator, many are in the process of hiring one for a full-time position. Others hadn't begun hiring yet because they were waiting until RACs become active in their area. Others reported that two or more staff members shared the full-time position.

Coding and compliance were the most popular backgrounds for the coordinator position.

Senate Reform Bill Would Expand RAC Program
Hold on to your stethoscopes: The Senate Healthcare Reform Bill is expanding the RAC program.

Specifically, Section 6411 of the Patient Protection and Affordable Care Act (H.R.3590, pp. 1777–1783) broadens the current RAC program to cover Medicare Parts C and D as well as the Medicaid program—by December 31, 2010.

Similar to the current Medicare RAC program, the Medicaid RACs would be paid by contingency fee to identify under- and overpayments, and would recoup those overpayments. States would contract with one or more RACs to seek out payment errors, and each state must have "an adequate process for entities to appeal any adverse determination made by such contractors," according to the Senate healthcare reform bill.

The Patient Protection and Affordable Care Act also provides several new requirements for contractors involved in the RAC program for Medicare Parts C and D. Per the bill, RACs must:

• Ensure that each Medicare Advantage plan under Part C and each Part D prescription drug plan has an antifraud plan in effect, and review the effectiveness of that plan.
• Examine claims for reinsurance payments under section 1860D–15(b) of the Social Security Act to determine whether prescription drug plans submitting the claims incurred costs greater than those allowable under paragraph 2 of the section.
• Review estimates submitted by private insurers for their prescription drug plans regarding the enrollment of high-cost beneficiaries, and compare them with the numbers of such beneficiaries actually enrolled.