Do not get a technical denial.
This was the advice provided by Stacey Levitt, RN, MSN, CPC, director of patient care management at Lenox Hill Hospital in New York City, who spoke during the HCPro audio conference “Medicare Appeals: Overturn RAC Denials Using the Medicare Appeal Process” on Tuesday.
Hospitals will see that RAC technical denials can have a large impact on their bottom line, said Levitt. And many times they are completely avoidable.
Technical denials can result when a RAC denies a claim for insufficient documentation—for instance, if the RAC never receives requested medical records from a provider.
CMS considers technical denials to be payment errors, because it has paid for care that cannot be substantiated, Levitt said.
"Documentation to support a service is required to meet medical necessity, and technical denials are similar to that," said Levitt. "If you don’t have the documentation written down and available, it doesn't support the care that has been done and you’ll get a denial."
Pay attention to the remark codes on your remittance advice to know whether your denial was a technical one, Levitt advised. N102 indicates requested medical records were not received (or not received on time), whereas N432 is for the adjustment based on a Recovery Audit.
If you do find an N102, you may be able to speak to your RAC during the discussion period about turning in additional documentation in certain circumstances. Some RACs have indicated during outreach sessions that they will accept missing documentation after the initial submission deadline. RACs may choose to accept relevant information that providers originally neglected to file.
While providers should do their best to avoid technical denials, Levitt knows firsthand that any hospital can slip up. At her former hospital, Levitt discovered they submitted incomplete documentation to a RAC after a copy service didn't realize the hospital charted on both sides of its paper medical records. The service copied the records as if there was only information on one side.
"When I would get 150 pages of a chart, I’d assume everything was there," said Levitt. But when she looked more closely she discovered the error. "I can’t tell you the amount of work that created, plus the costs added up. And it can delay your appeals."
But whenever possible, limit the possibility of a technical denial by meticulously tracking all deadlines for record submissions and by being careful and thorough when submitting records to ensure documentation is complete. Few hospitals can afford unnecessary loss.