A Command Performant(s): RAC Audits on the Rise
As we approach the conclusion of another transformative year, we are excited to present our comprehensive year-end review, shedding light on the trends shaping the healthcare market in 2023. Our team’s keen insights and...more
Report on Medicare Compliance 30, no. 2 (January 18, 2021) - Recovery audit contractors (RACs) may soon be auditing positron emission tomography (PET) for initial treatment strategy in oncologic conditions for compliance...more
Late last week, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment System (“OPPS”) final rule [CMS-1717-FC]. While many hospitals had hoped for relief from recent...more
The federal government recently awarded new contracts for Medicare recovery audits, and recovery audit contractors (“RACs”) will start showing up at hospitals, home health providers, and other facilities any time. But this...more
Last week, a number of health care industry associations sent letters to Congress detailing ways in which the government could relieve them of the burdens associated with “red tape.” The letters are in response to the first...more
On February 9, 2016, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit reversed a district court’s dismissal for lack of jurisdiction in the American Hospital Association v. Burwell case. ...more
While providers would certainly feel the pinch from the FY 2017 budget request submitted by President Barack Obama, hospitals have some new hope on receiving funds tied up in the Recovery Audit Contractor (RAC) appeals...more
On October 30, 2015, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2016 Outpatient Prospective Payment System Final Rule (2016 OPPS Final Rule). In the 2016 OPPS Final Rule, CMS finalizes...more
On October 15, 2015, CMS released its annual recovery auditing report to Congress. CMS’s Recovery Auditor (RAC) program identifies and corrects improper payments through a combination of prepayment and post-payment reviews,...more
Last week, CMS released its report to Congress regarding the results of the FY 2014 Medicare Recovery Audit Program (the “Report”). Of note, the Report notes that RACs identified and corrected more than 1 million claims for...more
Quality Improvement Organization Releases Guidance on Short-Stay Reviews – As previously reported, in July 2015, CMS announced that Quality Improvement Organizations (QIOs) would begin conducting reviews of certain inpatient ...more
In August 27, 2015, the U.S. Department of Health and Human Services (HHS) released the long-awaited and much-anticipated proposed 340B Drug Pricing Program (340B Program) Omnibus Guidance (Proposed Guidance). The Proposed...more
On July 8, 2015, the Centers for Medicare and Medicaid Services (“CMS”) released a Proposed Rule regarding the 2016 Hospital Outpatient Prospective Payment System (“OPPS”). The Proposed Rule, in addition to proposing updates...more
On July 1, 2015, CMS released a Proposed Rule that would revise the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System payment rates for calendar year (CY) 2016, and would...more
On July 1, 2015, the Centers for Medicare & Medicaid Services (CMS) released proposed updates to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for Calendar Year...more
The Medicare Payment Advisory Commission (MedPAC) released its “Report to the Congress: Medicare and the Health Care Delivery System” on June 15, 2015. As previously reported, the report makes recommendations for policy...more
On May 20, 2015, the Senate Special Committee on Aging held a hearing entitled “Challenging the Status Quo: Solutions to the Hospital Observation Stay Crisis.” Chairman Susan Collins (R-ME) and Ranking Member Claire...more
The Centers for Medicare and Medicaid Services (CMS) had planned to award new contracts to companies that act as Medicare’s recovery audit contractors (now referred to as recovery auditors) (RAs) for operation of the Medicare...more
In March 2014, CMS temporarily suspended the Recovery Audit Contractor (RAC) program until it secured new contracts. The contracts for the program expired in June 2014, and in August, CMS said that it would restart the...more
The Center for Medicare and Medicaid (CMS) announced that the new RAC contracts in North Carolina should be ready by the end of the year. This means that, next year, RAC audits on hospitals and other providers will...more
This year critical access hospitals (CAH) have struggled to implement procedures to comply with both the "two-midnight" rule and the 96-hour physician certification requirement. The combination of both puts physicians in a...more
Here’s how the catch works. A hospital admits and treats a Medicare patient who needs care. The hospital bills Medicare and gets paid. Later—usually much later—a RAC auditor rules that the patient needed only outpatient care...more
Since the advent of Medicare in 1965, hospitals have bemoaned the cost and burden of Medicare audits. The complaints increased when CMS hired private contractors for the audits. They became deafening in 2009 with the advent...more
Under the controversial program private contractors audit hospitals and other Medicare providers for fraudulent and erroneous Medicare billing. Why is it controversial? Because the auditors are paid a percentage of...more