RAC issue for IRFs has moved from being proposed to being approved.
The Centers for Medicare & Medicaid Services (CMS) recently posted a potential Complex Medical Review for (inpatient rehabilitation facilities) IRFs. The issue: 0A024-Inpatient Rehabilitation Facility (IRF) Stays: Meeting Requirements in the proposed Recovery Audit Contractors (RAC) Topics list on the CMS website. On Sept. 11, 2018 that issue was moved to the Approved Topics list and IRFs can now expect to receive Additional Document Requests (ADRs) from the RAC.
Who is Affected?
The approved review will affect all regions and all states so ultimately every IRF will be open for review.
How Will We Know When Our Region Begins Audits?
The table below, copied from the CMS Website, lists the RAC Regions with links to each RACs website.
|
Region |
States |
Websites |
|
Phone Number |
|
Region 1 Performant Recovery, Inc. |
CT, IN, KY, MA, ME, MI, NH, NY, OH, RI, and VT |
1-866-201-0580 |
||
|
Region 2 Cotiviti, LLC |
AR, CO, IA, IL, KS, LA, MO, MN, MS, NE, NM, OK, TX, and WI |
1-866-360-2507 |
||
|
Region 3 Cotiviti LLC |
AL, FL, GA, NC, SC, TN, VA, WV, Puerto Rico and U.S. Virgin Islands |
1-866-360-2507 |
||
|
Region 4 HMS Federal Solutions |
AK, AZ, CA, DC, DE, HI, ID, MD, MT, ND, NJ, NV, OR, PA, SD, UT, WA, WY, Guam, American Samoa and Northern Marianas |
Part A: 1-877-350-7992 Part B: 1-877-350-7993 |
As of Sept. 18, 2018, none of the RACs have yet posted details on these reviews on their website. We’ll be checking regularly, however, and will update readers when the RACs post information.
So, What Now?
The reviews would impact RAC Regions 1-4 in all states and will likely include a review of how well the IRF meets the Jan.1, 2010 clarifications for reasonable and necessary care in an IRF – the same areas that have been consistently reviewed by Medicare Administrative Contractors (MACs) in Probe & Educate reviews, by Special Medical Review Contractors (SMRC), and in the current Targeted Probe and Education program (TPE). IRFs should watch the websites and our updates for updates to the issues and details of these audits.
The Bottom Line
Clear, complete and timely documentation continues to be the IRFs best defense for ongoing audits. Additionally, a clear process for responding to document requests to assure that the required documentation is submitted in a timely manner will aid the IRF in successful audit performance.
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