RACs have begun auditing at this point, and providers in some states may have received their first denial letters this week. But many providers seem to still be waiting, holding their breath, and worrying whether the mail carrier might deliver their first RAC demand letter(s) that day.
However tempting it may be to simply wait, providers can still use this time effectively while they wait. Consider the following tips from several RAC experts:
Verify your contact information with your RAC. Yes, you may have submit your contact information to your RAC months ago, but use this time to verify your RAC has the information and it is correct, says Yvonne Focke, RN, BSN, MBA, director of revenue cycle and integrated care services at St. Elizabeth Healthcare in Kentucky. Focke submitted her preferred contact information for all RAC correspondence months ago, but recently discovered her RAC didn't have the information. Checking to make sure the RAC has your information is especially important if you are part of a large health system. And try to get written or e-mail confirmation from your RAC verifying it has the correct information on file for your organization, says Focke.
Test your processes and those of your vendors. Send yourself a test RAC letter to see where it ends up and when, says William L. Malm, ND, RN, healthcare consultant for Craneware. You will see where a real RAC letter might get hung up and you'll be able to adjust accordingly before the real thing arrives. Malm calls this the “Zero dollar test”— it costs nothing but a $.44 stamp, and can teach you so much about your work flow. RACs are testing themselves right now, and providers should be doing the same, he says.
Form good habits. Take this opportunity to form habits now that will help you later, says Tanja Twist, MBA/HCM, director of patient financial services at Methodist Hospital of Southern California. For instance, it may sound simple, but providers should be checking their RAC's Web site regularly, watching for any updates/changes. Providers should get into the habit of doing this now before the auditing begins so it will become part of their regular routine.
Share what you know. RACs have posted approved issues for most states at this point. So do something with that knowledge, says Nancy Beckley, MS, MBA, CHC, of the Bloomingdale Consulting Group, Inc. Educate staff members who may work in high-risk areas subject to automated review in your state (e.g., speech or physical therapy, OB-GYN, etc.). Go over the necessary pathway from service delivery to data entry, from edit tables to bill drop, etc. This will help pinpoint potential problems from both clinicians and finance in those areas RACs have identified as targets.
Prevent high-dollar medical necessity denials while there's still time. To prevent high-dollar admission necessity denials, take a close look at current processes for evaluating and supporting accurate level of care determinations (e.g., inpatient, outpatient, outpatient with observation services), says Deborah K. Hale, CCS, president and CEO of Administrative Consultant Service, LLC. To accurately respond to improper level of care determinations prior to patient discharge, a hospital's utilization review (UR) committee responsibilities should be compared with the Medicare's Conditions of Participation for the UR Committee (CoP 482.30) and make any necessary corrections, she says.
Review Medicare Transmittal 107, 1760 (effective July 1) and 1803 (effective October 1) to ensure you are evaluating medical necessity and issuing condition code 44 in a manner consistent with the Medicare Benefit Policy Manual, Chapter 1. In particular, note Transmittal 1803, which clarifies the need for the involvement of two physicians—the first being the physician who makes the medical necessity determination and who may not be the treating physician, and the second being the attending physician, says Joe Zebrowitz, MD, executive vice president for Executive Health Resources.