Recovery Audit Contractors (RACs) in some parts of the U.S. have begun requesting documentation from certain skilled nursing facilities (SNFs), which suggests that the Centers for Medicare and Medicaid Services (CMS) may be ready to unleash the RACs on SNFs with designated levels of High Therapy RUGs utilization. Under the federal Recovery Audit Contractors program, the RACs are permitted to audit providers only on CMS-approved issues. To date, the Ultra High Therapy Resource Utilization Groups (RUGs) issue is not on the CMS-approved list of audit topics.

However, CMS now permits the RACs to also request records and to audit up to 10 “test claims” to determine if CMS, based on the results of the test audit, should add a new audit focus to its approved list. At least one RAC has begun issuing documentation requests to SNFs on this issue. The RAC at issue does not cover North Carolina. However, once an audit focus is on the CMS-approved list, any RAC can audit that issue, so it’s important to know what RACs in other parts of the country are doing.