What can providers do now?
In terms of anticipatory planning and preparation, there are a number of different things for providers to consider, says Lamkin.
"First, providers should stay on top of the general Medicaid billing rules, not just RACs and appeals, and they should also conduct real-time, open chart audits to ensure accurate and compliant documentation," she says. "In addition, it may be beneficial for a provider to have someone on the front end at registration that is qualifying and screening potential Medicaid recipients."
"While real-time management of the bed placement and appropriate documentation are crucial to getting the rules right on the front end, measurement of accuracy and exchange of information are equally important for long-term success and accountability."
There must be some type of structure that brings together the finance, clinical, and utilization review functions, Lamkin says. All roles related to billing compliance should serve on the billing/compliance RAC committee or any other type of centralized committee.
It will be important for everyone to see the big picture when as the hospital determines how to handling the Medicaid auditing process. This is where enterprise-wide performance improvement of the process is housed, she added.