On Monday, the Centers for Medicare & Medicaid Services (CMS) announced new RAC contract awards as follows (see image from CMS below):
- Region 1 - Performant Recovery Services
- Region 2 - Cotiviti LLC (formerly known as Connolly Consulting)
- Region 3 - Cotiviti LLC (formerly known as Connolly Consulting)
- Region 4 - HMS Fedral Solutions
- Region 5 - Performant Recovery Services
For inpatient acute-care hospitals, the new RAC program is not likely to run as wide-open as it did 2010-2014. CMS is limiting the lookback period for the highly lucrative (from the RACs’ perspective) short-stay inpatient claims. CMS is also limiting additional documentation requests (ADRs) across facilities and claim types so that one area of a large health system is not unduly burdened.
For other providers, expect the story to be much different. Inpatient hospitals received most of the attention between 2010 and 2014 while other areas of the Medicare payment system were ignored.
Hospice, for example, was virtually unaudited by RACs despite being an area identified by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) and press reports as prone to abuse and possible fraud. Home health agencies have also experienced less auditing relative to inpatient hospitals and will likely be an area of focus under the new RAC contracts.
The impact RACs will have on less concentrated areas of Medicare such as hospice and home health will likely be magnified by the absence of an infrastructure to handle claims reviews. Most inpatient hospitals have compliance specialists able to manage the RAC reviews, while home health and hospice providers may not.
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Chuck Buck is the publisher of RACmonitor and the executive producer and program host of Monitor Mondays.
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