Ephrata Community Hospital (Ephrata) is a small 130-bed community hospital located in northern Lancaster County, Pa. Servicing the heart of Amish Country, it is the only Pennsylvania hospital to house a barn on its main campus.
Completing a small health system is the Northern Lancaster County Medical Group, Ephrata Community Home Care and Ephrata Medical Equipment. Despite its small size and limited resources, Ephrata has worked diligently on preparing for the start of the RAC auditing process.
Here at Ephrata the compliance department is comprised of the compliance officer, a nurse auditor, two compliance auditors and an external audit coordinator. This is the team that implements the compliance program, performs internal audits and investigations, and responds to external audit requests.
Although Ephrata is a late starter in the permanent RAC program, the hospital established a centralized process for handling all external audits, including the purchase of a Web-based application specifically designed for tracking audits, monitoring audit deadlines and trending audit results.
In the Beginning
Prior to receiving its first RAC records request, the only RAC activity Ephrata had experienced was the receipt of a letter rescinding four RAC recoupments made in December 2010. Surprised to have discovered that RAC recoupments had taken place, Ephrata contacted DCS, the Region A RAC. DCS was unable to provide an explanation as to why the recoupments had been rescinded; our best guess was that the cases fell outside the three-year lookback period.
The hospital received its first RAC records request on April 8, 2011: Twenty-six letters requested 116 records within 45 days. There was nothing unusual about the request except that it was delivered smack in the middle of the MAC post-transition blackout period.
In the Dark
The blackout period has been described as 90 days before and after the transition date, whereby Ephrata's fiscal intermediary on Feb. 21, 2011 would change from Wisconsin Physician Services to Highmark Medicare Services.
Although we were prepared to respond to this first RAC records request, we were not expecting RAC activity during the blackout, and so contacted Scott Wakefield, CMS's RAC Region A project officer. Wakefield replied that because this was a contractual provision with the RAC and not a regulatory issue, CMS would have the discretion to alter its approach in order to lessen the impact of the transition on the RACs.
Ephrata is continuing to respond to the request and anticipates no difficulty in meeting the deadline. However, this sudden change to the program, made without any notice to providers, seems contrary to the transparency promised by CMS when the pilot RAC program became permanent.
A word of advice to those who have not yettransitioned to the MAC for their region: Don't count on the time afforded by the blackout period for RAC preparation.
Get ready now!
About the Author
Susan Parker, MHA, is a corporate compliance officer at Ephrata Community Hospital, a small rural facility in Lancaster County, Pa. She holds a masters degree in health administration from Penn State University and is certified in healthcare compliance and as a legal nurse consultant. Her introduction to compliance began while working in the consulting field, first on the payer side and later on the provider side. In 2004 Susan joined the provider community as a member of the internal audit department for a local health system. She assumed her current position as director of corporate compliance in 2006.
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