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
Please see full publication below for more information.
