In addition to all of these issues, another challenge that many leaders may be facing is "how do we keep RACs in front of everyone?" For those of you preparing for RACs on a daily basis, this may seem like a strange question; however, for those individuals who have multiple "priorities," it is important to be reinforcing the RAC, ZPIC, MIC, etc. message. I believe this is a vital issue because the RACs have not "hit yet" in many parts of the country.
If you haven't done so already, I would suggest forming a RAC Steering Committee (RSC) to reinforce the importance of RACs and to guide/inform your organization's leadership about all of the preparation, education, corrective action and continuing monitoring activities that should be occurring. Here are some suggestions and tips on how your RSC could be structured and utilized.
You may want to consider the following individuals to participate in the committee: chief financial officer, chief compliance officer, physician champion, health information management director, information technology representative, finance director, RAC coordinator, hospital coding director, physician coding director, reimbursement director, physician practice management director, business office director, legal director, utilization review director, internal audit director and applicable outside consultants (to consider on an invite basis).
This list is just a suggested guide and by no means is meant to be all-inclusive. Other individuals perhaps should be added depending on the specifics of your institution.
Depending on the structure of your organization, this person could vary, however the individual selected should have the time available to perform necessary duties and the management skills necessary to organize and run an effective committee meeting. Their other responsibilities should include holding individuals accountable for tasks, creating goals, managing expectations and being able to handle unpopular topics in a diplomatic fashion.
Commonly selected committee chairs include a chief financial officer, chief compliance officer and RAC coordinator. Some organizations, due to the complexity of certain relevant issues, have decided to outsource chair duties to outside experts. This has some obvious advantages, while the primary disadvantage is cost.
The establishment of an RSC agenda is an important step toward ensuring that all important topics are being covered. Items you might want to consider for agenda inclusion include the following:
- Review and approval of previous meeting minutes (yes, I am recommending keeping minutes)
- RAC educational updates - what has happened since the last meeting? Consider reviewing in real-time your RAC's Web site and the CMS RAC Web site for updates and information. Don't forget to ask - how will this information be disseminated among your colleagues? Should you consider an internal intranet site on which this information can be housed? What type of internal education is needed?
- Physician education issues - what issues require attention to ensure that members of your medical staff understand the RAC threat and the need to document appropriately?
- Record request(s) receipt and status - discussion and analysis of current RAC activity at your facility, the dollars at risk and your response to these requests.
- Tracking of your claims - whether you are doing this internally or have purchased software, this is the perfect venue in which to update staff.
- Member updates - all members should be held accountable for certain tasks and given the opportunity to speak about progress.
- Chart review activities - give updates on statuses of internal reviews of appropriate risk areas to determine compliance with Medicare regulations.
- Corrective actions - identify problems with noncompliant activities identified either internally or by the RACs, MICs, ZPICs, etc. What are you doing to correct these issues? Who is accountable? What timelines have been set to reexamine the issues to determine whether they have been corrected?
- Open discussion
- Next scheduled meeting - recommend monthly meetings at a minimum
I recommend that minutes of the meetings be kept and disseminated to the group as drafts. Obviously, as with most committee minutes, there may be certain discussions that should not be included in these documents. The value of the minutes is that they represent additional documentation of the efforts your organization is taking to ensure that your billing and coding activities are compliant. If you do have a billing or coding problem that gets identified by an outside agency, these types of documented efforts may assist your counsel in legal defense against threats of fines and penalties.
Effective planning and management of your RAC defense initiatives requires structure and coordination of all of your institution's efforts. The formation of an organized RAC steering committee led by someone who can manage issues and people effectively may be a viable tool for your institution to use. In addition, it should serve to remind your leadership that the RAC defense needs to remain a priority for your institution.