If you think through the steps you will undergo in a RAC audit, you can begin to identify what functionality you may need and/or want in tracking software. Below is a list of some of the basic functionality of RAC tracking software you may want to consider.
Perhaps the primary reason for utilizing tracking software is to ensure that deadlines are met, because missed deadlines mean upheld denials with no recourse for appeal. Review how various forms of tracking software manage and notify users of pending deadlines. Some may feature "flags" that offer obvious warnings when the software is accessed, while others may send email notifications as deadlines approach. You also may want the flexibility to change deadlines from the RAC program deadlines so you can track other audit activity featuring different deadlines.
Managing Accountability and Workflow
Accountability for the RAC audit process is also critical. Tracking software should allow for assignment of specific tasks and responsibilities, such as documentation review to key staff. As mentioned above, some systems may include email compatibility, so notification of required follow-up tasks is sent directly to the responsible party.
Ensuring the Security of Records - Be aware of where tracked data will be stored, how security will be ensured and that your security policies are being followed - by you and by the tracking software vendor alike, if the tool is an online tool.
AHA RACTrac Compatible
For hospitals, we recommend that you choose a program that is compatible with AHA RACTrac. A list of compatible vendors can be found online at http://www.aha.org/advocacy-issues/rac/ractrac.shtml. As of the writing of this article, the list was current to January 2012, but an updated list should be available soon.
Managing the RAC process also requires that the team overseeing the process has access to continuously updated reports and scorecards with key information related to audits. The system should allow for report modification to highlight indicators important to your organization, and reports need to be downloadable in a format that can be shared with key staff.
If your software will have multiple users or your organization has multiple locations and/or provider types, select a tool that is scalable and appropriate to the size of your organization. Consider whether a desktop or online tool best suits your needs.
As you well know, RAC audits are not the only audits to be managed. Select software that has the flexibility to track self-audits and other third-party audits.
The risk RAC audits present lies not only in recoupments, but in the hidden administrative costs to your organization. Some of these costs are obvious - the salary of a full-time RAC coordinator, fees for documentation submission, costs of external chart audits, legal fees for appeals, etc. - but many are hidden departmental costs. You may want a tool that tracks how much time your staff spends on collecting, copying and submitting documentation as well as performing documentation review specific to audits and appeals. This information can be used to calculate additional hidden costs to your organization specific to RAC audits.
If you want to include actual electronic files as part of tracking - medical records, appeal letters, scanned letters from RACs/MACs, etc. - look for software that will allow you to scan or upload your documentation for access during tracking and for documentation submission. You also might consider software that may not "house" the electronic files, but will allow you to create links (shortcuts) to files already on your servers.
Submission of Documentation
Now that esMD services are available from multiple vendors, determine if you will submit documentation electronically or via a carrier such as FedEx. Your tracking software may include the functionality to submit documents directly from the tool, or it may launch a separate application or website for your esMD gateway. Approved esMD gateway providers are listed on the CMS webpage online at http://www.cms.gov/esmd (under the link "Which HIHs Offer esMD Gateway Services to Providers?")
Some tracking software includes a database of current RAC vulnerability issues and allows you to use your current and ongoing claims data to determine your level of takeback risk. The information can help you identify which cases may be at risk going forward and where you can focus improvement activities to reduce risk to future claims.
Installation and Maintenance
Determine how the software will be installed and maintained over time, and how you will access software upgrades. Be aware that installation and ongoing support costs may come in addition to the purchase price. Based on the available support, determine the role your internal IT department may play in installation and performing maintenance.
There is great variability in price for RAC tracking software, from a few thousand dollars to tens of thousands of dollars, depending on functionality, system integration and add-on services. Consider your organization's specific risk for takebacks and how much risk you might mitigate by better tracking your activity.
This is by no means a fully comprehensive list of functionality, but it is provided as a starting point to determining the functionality that is right for your organization. In the spirit of full disclosure, my organization, PACE Healthcare Consulting, LLC, is one of the vendors on the AHA RACTrac compatible list (with its RACTelligenceTM Tracking software), but I also know there is no one-size-fits-all solution for healthcare providers.
About the Author
Amanda Berglund, MS, MBA, is a partner in PACE Healthcare Consulting. Prior to joining PHCC, Amanda was Associate Administrator and Chief Business Development Officer at North Fulton Regional Hospital near Atlanta, GA. She is a former Manager of Business Development for Tenet Healthcare Corporation. Amanda received a BS from Columbia University and an MS from Georgia Institute of Technology. She also has an MBA in entrepreneurial leadership from Nova Southeastern University.
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