Performant, the Recovery Audit Contractor (RAC) Ask-the-Contractor Teleconference (ACT) – June 8, 2022
View the handout for the June 8, 2022, Performant, the Recovery Audit Contractor (RAC) Ask-the-Contractor Teleconference (ACT).
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- Are our overturned appeals, communicated to the first round of reviewers so they stop denying things that are obviously appropriate?
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Yes, if we are seeing high overturn rates, we certainly are going to go back and do education amongst our auditors. Each month, we do a review of our overturn rates.
Published: 06.22.22
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- I'd like to know the type of RAC reviews that are being done in Home Health and Hospice.
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You can find the CMS approved audit issues for Home Health and Hospice at: https://www.performantcorp.com/cms-rac/cms-rac-resources/cms-approved-audit-issues/default.aspx#Region-5
Published: 06.22.22
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- Is it helpful to note which requirement a document is filling? i.e. progress note prior to the DOS that has an order in it?
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Yes, please provide all relevant information when submitting your documentation.
Published: 06.22.22
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- Is this information applicable to all RACs? We have Health Management Systems as the RAC.
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Your RAC will have a different website, however, all RACs abide by the same guidelines, the same audit review issues, and the same look back periods. All four RACs should be in sync with one another and reviewing consistently across the board.
Published: 06.22.22
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- What do we do if we agree with your findings when we receive your audit? (our billing/documentation was wrong)
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In these instances, instead of sending records, you can send a letter explaining a request for records for letter ID, claim #, was received and we agree that this was a billing error. This information will be uploaded into our system and the claim will go through a technical denial. We are required to wait 30 days.
Published: 06.22.22
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- What triggers this type of audit? How can therapists effectively document to avoid failing these types of audits?
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RACs review the CMS approved issues. You may be chosen for an audit if you have submitted claims for these issues. As far as documenting, a general rule is to make sure your documentation matches the services provided during your encounter with the patient.
Published: 06.22.22
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- Where is the RAC getting their coverage criteria? Denials we receive are their own interpretation of the LCD.
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The RACs and the MACs follow the CMS guidelines and try to avoid discrepancy by interpreting those guidelines the same way. If a provider disagrees with our interpretation, please contact us through the customer service team at info@performantrac.com. Our subject matter experts will review the issue. If we find that the MAC appeal overturned rates are high, we will contact the MAC and possibly CMS for clarification on the interpretation.
Published: 06.22.22
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- Where to find info like: How often can request records and limit on how many per hospital?
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This information is found in the external resources section of Performant's website: https://www.performantcorp.com/cms-rac/cms-rac-resources/cms-rac-provider-resources/. On this page, you will find CMS website links that explain how ADR limits are calculated and how often records can be requested. Also, you can find your ADR limits in the RAC portal, and if Performant sends you a letter, you will see your ADR limits within the letter.
Published: 06.22.22
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- The agency I work for has multiple office in several states. We have gotten conflicting information from CGS and NGS on the Face-to-Face requirement from a community referral source. If there is different guidance, what are you doing by and why is there different guidance?
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The RACs and the MACs follow the CMS guidelines and try to avoid discrepancy by interpreting those guidelines the same way. You can find face-to-face guidance in the Medicare Benefit Policy Manual (CMS Pub. 100-02, Ch. 7) section 30.5.1.1 at: Medicare Benefit Policy Manual (cms.gov). If a provider disagrees with our interpretation, please contact us through the customer service team at info@performantrac.com. Our subject matter experts will review the issue. If we find that the MAC appeal overturned rates are high, we will contact the MAC and possibly CMS for clarification on the interpretation.
Published: 06.22.22
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- Where can we find that reference page that tells us where the RAC's guidelines/descriptions that were up on the screen?
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The reference pages are located here: https://www.performantcorp.com/cms-rac/cms-rac-resources/cms-rac-provider-resources/.
Published: 06.22.22
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- Is the RAC penalized when a denial is overturned at the MAC or QIC level?
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Yes, there is a monetary penalty. We will not be paid any kind of contingency.
Published: 06.22.22
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- We have been getting an overwhelming number of denials from the RAC on records that clearly meet the Medicare LCD requirements. 99% of them are overturned on redetermination or reconsideration. What recourses is the RAC using when completing reviews? From what we are seeing, they are making their own interpretation of the LCD and denying claims base on this. Who do I contact if I believe there is a discrepancy?
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You can file a discussion period if you feel like it's been inappropriately denied. Please complete the discussion request form found under Supporting Resources here: https://www.performantcorp.com/cms-rac/cms-rac-resources/cms-rac-provider-resources/. If your discussion period outcome upholds the denial, and you still disagree, you can file an appeal with the MAC to stop that recoupment from happening. If you have questions or a concern, you can always e-mail us at the RAC info box: INFO@PERFORMANTCORP.COM
Published: 06.22.22
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- We have about 140 providers and a LOT of RAC misrouted letters. And are constantly receiving information late. Will I need to have a different provider portal for each doc?
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It is NPI based, however if you represent multiple facilities/providers, please visit https://www.performantcorp.com/cms-rac/Update-Provider-Contact-Information/default.aspx. You can complete the form for each facility/provider or complete the Excel spreadsheet found on the webpage. If you utilize the Excel spreadsheet, email the completed form to our RAC Customer Service Team at INFO@PERFORMANTCORP.COM and we will update the addresses for you.
Published: 06.22.22
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