Under provisions of the Competition and Contracting Act of 1984 (CICA), the GAO had 100 days in which to review the protest and reach a decision.
Just one month earlier, in October, CMS formally announced its selection of permanent contractors and provided details of its launch on its Web site.
The four permanent RAC contractors include the following:
- Diversified Collection Services, Livermore, Calif., which would initially cover Maine, Massachusetts, New Hampshire, New York, Rhode Island and Vermont
- CGI Technologies and Solutions, Fairfax, Va., for Indiana, Michigan and Minnesota
- Connolly Consulting Associates, Wilton, Conn., for Colorado, Florida, New Mexico and South Carolina
- HealthDataInsights, Las Vegas, Nev., for Arizona, Montana, North Dakota, South Dakota, Utah and Wyoming
Additional states will be added to each RAC region in 2009, according to CMS.
Before the stay had been initialized, CMS was advising providers to conduct internal assessments to ensure that submitted claims meet Medicare rules. Other steps CMS advised at the time included:
- Identifying where improper payments had been persistent by reviewing the RACs' Web sites and identifying any patterns of denied claims within their practices or facilities.
- Implementing procedures to respond promptly to RAC requests for medical records.
- Filing appeals before the 120-day deadline in the case that a provider disagrees with the RAC determination.
- Keeping track of denied claims and correcting previous errors.
- Determining what corrective actions need to be taken to ensure compliance with Medicare's requirements and to avoid submitting incorrect claims in the future.
The 3-year RAC demonstration program in California, Florida, New York, Massachusetts, South Carolina and Arizona collected over $900 million in overpayments and nearly $38 million in underpayments returned to health care providers.