The Recovery Audit Contractor (RAC) Program is beginning its rollout in Yellow and Green States. A feature of the RAC Program in its permanent state is the explicit promise of Provider Outreach Sessions. In fact, the RAC review process cannot start until Provider Outreach sessions have been completed.

According to CMS,

"As part of preparing Medicare providers for the RAC program as it is phased in nationally, CMS will continue working closely with national and state medical, hospital and nursing home associations to strengthen relationships to be more proactive and anticipate the needs and concerns of health care providers. Before work begins, the RACs will hold Town Hall type meetings in each state with health care providers and CMS staff and representatives from the RACs..."

The three-page Provider Outreach schedule was initially posted on the CMS RAC Web site in mid-March. This initial listing of outreach meetings (listed by region) was further modified to include conference name, attendee type, location, and presenters. It appeared that most outreach sessions were designed for hospitals and physicians; and most were listed as being hosted by hospital associations and medical societies.

Glimmer of Hope

Ahhhh, but a glimmer of hope: at the Atlanta CMS regional office, a variety of outreach sessions were planned not only for physicians, but also for hospice, home health agencies, and SNFs. Alas, this was not to be, at least for now. Let's look closer at the case of the disappearing and changing Provider Outreach meetings.

Unless you are representing a hospital or a physician practice, the door may be closed to your participation. Non-hospital providers found that sessions hosted by hospital associations and medical societies were ‘members only.'

How can non-hospital (and non-physician) providers participate in this process? Was it really the intent of CMS in having RAC provider meetings that are non-inclusive of the providers subject to RAC audits?

Although a Provider Outreach meeting was listed for Florida, and sponsored by the Florida Hospital Association, it was impossible to register at the association's Web site unless you were an employee of a Florida hospital.

Open Door Forums

Well, there was always the RAC Special Open Door Forums (ODF), with one scheduled for Part A and one for Part B in mid-April. CMS warned of limited phone capacity, and the Part A call was closed to callers nearly 15 minutes prior to the start time as reported by unsuccessful callers.

The Part B ODF seemed to have more capacity. CMS staff made presentations, and noted that the RAC representatives were on the line, but only participating as listeners. (No questions please!) During the Q & A portion there was a question from a Part A provider, who said he was only listening because he was locked out of the Part A call. CMS reassured him, stating that the same information was presented in both sessions, implying that he didn't miss anything. That seems odd, so let's check the recording of the Part A ODF that was supposed to be posted on April 16th and available for 30 days. Not there. So there is no way at this time to review the Part A call. The Part B ODF information is also missing in action from the CMS Special Open Door Forum Web site, and it should have been posted yesterday (April 22).