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.
Connolly has posted a new document detailing the requirements for submitting medical records. Below is a portion of the requirements, concerning what should be put on CD or DVD:
- Scanned image resolution must be 300 dpi and in black and white
- Image format must be in either TIFF or PDF format
- One image per medical record, i.e., multiple-page image file. (For example, a two hundred page medical record will be one file.)
- The image file name must be the requested claim number. (For example if the claim number 123456 is requested, the filename would be 123456.pdf or123456.tif )
- A copy of the Medical Record Request Letter
Any disk submitted must include a "metadata" file, as an Excel file or a Tab-delimited Text file. If this metadata file is omitted, Connolly will reject the entire CD/DVD. The file must also include the following data, and there should be exactly one entry in the metadata file per image submitted on the disk:
- Requested Claim Number
- Begin Date of Service
- End Date of Service
- Patient name (first and last name)
- Patient DOB
- Patient HIC Number
- Patent Account/Control Number
- Medical record number
- Provider Name (full name)
- Provider Number
- Provider NPI
- Number of pages or the file size of the image submitted for acknowledgement purposes
- Total number of medical records on the CD/DVD
According to the document posted, Connolly will confirm receipt of CD/DVDs via fax and/or email to the provider's medical record contact person on record with Connolly. Keep in mind, however, that Connolly must still validate the data on the CD before they accept it. Receiving the CD/DVD is only part of the process.
Their confirmation will include the following information:
- CD/DVD Name
- Received Date
- Processed Date
- Status: Accepted/Rejected
The whole CD/DVD will be rejected if it fails validation. Reasons for rejection include file count mismatch, page count mismatch, or missing metadata file.
Therefore, a provider would be wise to validate the disk before sending it out to Connolly.
For a more detailed overview, including a look back at what RACs targeted during the demonstration project, consider the RAC Review & Wrap-up eCourse. The course can be purchased for $199.95 and includes a list of the main RAC targets, what they mean for your facility, plus some tips about how to prepare for audits of these areas. To register, visit: RAC University.
LIVE Webinar: May 20
Also consider RAC University LIVE, a live webinar about how to protect reimbursements for Cardiac Services in 1-day stays, scheduled for tomorrow (Wednesday, May 20). The webinar will concentrate on avoiding medical necessity errors in the documentation of such cases, using many examples from actual audits, performed by the experts at eduTrax. A facility or office can register for the live session for $195, or purchase a CD (with a 1-year site license) for $195, or both for just $295. To register, visit: RAC University.
Watch for news about more LIVE webinars and new courses posted to RAC University, powered by eduTrax®, to help prepare you and your staff for the coming storms that are the RACs.