CMS published Frequently Asked Questions (FAQs) related to the Medicaid Recovery Audit Contractor (RAC) program on December 30, 2011. CMS highlights significant sections of the Medicaid RAC final rule in this guidance and re-emphasizes that Medicaid RACs will not replace existing state Medicaid program integrity contractors. On September 16, 2011, CMS published the final rule in the Federal Register (76 Fed. Reg. 57808) which implements the Medicaid RAC program, as required by § 6411 of The Patient Protection and Affordable Care Act.

Medicaid RACs are required to identify overpayments and underpayments, and the deadline for States to implement their respective RAC programs was January 1, 2012. The CMS FAQs discuss, among other things...