Tips from the RAC Cave: "Pre-RAC Audits vs. RAC Preparation"

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If you have not already conducted a pre-RAC audit, don't initiate one now just

because of the RACs. Instead, focus your resources on RAC preparation

through identification and establishment of internal staff (the RAC Team) to

address the upcoming RAC attacks and development and implementation of

internal protocols and policies, to track and document the RAC audit and

appeal process. Of course, you should continue your routine or scheduled

internal audits pursuant to your compliance program. If you want to conduct a

pre-RAC audit anyway, then hire a consulting firm rather than a law firm. It's

usually more cost-effective. Depending on the audit topics, however, work with

your in-house or outside counsel to hire the consulting firm in order to maintain

attorney-client privilege. Remember: the RAC is a red herring if you discover a

billing compliance problem that implicates issues related to voluntary

disclosure and refund. In other words, if a billing compliance issue that could

require a voluntary disclosure or refund is identified during your preparation for

a RAC audit or as a result of a RAC review, your primary concern should

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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