By: Ernie De Los Santos

The Centers for Medicare & Medicaid Services (CMS) has cancelled four RAC Outreach Sessions scheduled for Texas in May over concerns about the H1-N1 flu virus.

None of the sessions were rescheduled, despite the need for almost 600 facilities and thousands of physician practices in the state to hear about the program and be able to ask questions of both CMS and the Recovery Audit Contractor (RAC) with jurisdiction over Texas, Connolly Healthcare.

Instead, a PowerPoint presentation of a conference call arranged by Texas Healthcare Association (THA) was made available.

Representatives of the CMS and Connolly recorded, on May 6, an orientation program as a substitute for programs that were cancelled. The recording includes helpful background information and tips from Amy Reese, CMS project coordinator for RAC Region C; Christine Castelli, Connolly Consulting; and Patricia Fenton, a consultant for CMS Division of Recovery Audit Operations.

New Information on RACs

The recording features a portion done by Connolly, which is the first time I have heard a direct representative speak to anything other than answering questions on a CMS call. The speaker for Connolly, Chrisitine Castelli, sounded personable and friendly, inviting providers to contact her directly with questions. During her presentation, she gave some new information and a few suggestions for providers that could smooth out the process for submission of records to Connolly.

Time Limits for Responding

RACs can perform two types of audits. The first kind, Automatic Reviews, do not require a human to review the medical record. Such reviews occur when coding or billing errors are found in the claims data alone, by the RAC, based upon NCDs, LCDs or other CMS rules and regulations - the same ones followed by all carriers, Fiscal Intermediaries (FI) or Medicare Administrative Contractor (MAC).

The second kind of review is the Complex Review, which requires that a human being review the medical record directly and then report to the provider on their finding. Once the RAC decides to perform a Complex Review, the provider is sent a letter requesting specific records to be copied and sent to the RAC.

The provider has a time limit of 45 days, plus 10 days for mailing, to get the records to the RAC.

Extensions to be Granted - Connolly

For the first time anywhere and by anyone that I've heard or read, Ms. Castelli stated that Connolly would grant extensions to the 55-day time limit, if the providers request such an extension.

This is meant, however, to be a once-in-a-while type of extension, granted under extenuating circumstances, which must be explained to Connolly. Connolly is under no obligation to grant such extensions, but Ms. Castelli made it appear that they are willing to work with providers under reasonable circumstances.

Take Advantage of Discussion Period

Mirroring what we've heard from CMS lately, she also made a point of encouraging providers to take full advantage of the "Discussion Period," a feature unique to the RAC Permanent Program. The discussion period is a time (of no set duration) during which the provider has a chance to talk to the RAC and convince them to, as Ms. Castelli said, "take the claim out of the queue."

The Discussion Period begins on the date of the Review Results Letter, issued by the RAC, to inform the provider of the results of their audit of requested records. She indicated that the period would have a length of "probably 30 days," but there is no set duration for it.

Nevertheless, it does seem to present a window of opportunity for the provider to avoid a denial, particularly if there are other records or information that, if provided to the RAC, might shed more light on the claim and thereby support its validity. Providers should watch these denials carefully and take full advantage of this unique feature of the program.

How to Submit Requested Records

There are finally some details about exactly how to submit medical records to Connolly. First, a Request for Contact Information Form has been posted and should be filled out by all providers. This will help insure that Connolly is sending information to the proper address and contact within your organization.

Find the form for Connolly, here. If you represent multiple providers or facilities, you should complete a form for each one. Additionally, there is another form meant for providers with multiple offices and/or facilities, also found here.

When submitting records to the RAC, Ms. Castelli suggested that the best method was to put them onto a CD or DVD, and then send them via a trackable courier, such as

FedEx, UPS, DHL, or registered USPS mail.