April 22, 2009

The RAC Not-So-Open Door Outreach Policy

By

nbeckleyBy: Nancy J. Beckley, MS, MBA, CHC

The Recovery Audit Contractor (RAC) Program is beginning its rollout in Yellow and Green States. A feature of the RAC Program in its permanent state is the explicit promise of Provider Outreach Sessions. In fact, the RAC review process cannot start until Provider Outreach sessions have been completed.


According to CMS,

"As part of preparing Medicare providers for the RAC program as it is phased in nationally, CMS will continue working closely with national and state medical, hospital and nursing home associations to strengthen relationships to be more proactive and anticipate the needs and concerns of health care providers. Before work begins, the RACs will hold Town Hall type meetings in each state with health care providers and CMS staff and representatives from the RACs..."


The three-page Provider Outreach schedule was initially posted on the CMS RAC Web site in mid-March. This initial listing of outreach meetings (listed by region) was further modified to include conference name, attendee type, location, and presenters. It appeared that most outreach sessions were designed for hospitals and physicians; and most were listed as being hosted by hospital associations and medical societies.


Glimmer of Hope

Ahhhh, but a glimmer of hope: at the Atlanta CMS regional office, a variety of outreach sessions were planned not only for physicians, but also for hospice, home health agencies, and SNFs. Alas, this was not to be, at least for now. Let's look closer at the case of the disappearing and changing Provider Outreach meetings.


Unless you are representing a hospital or a physician practice, the door may be closed to your participation. Non-hospital providers found that sessions hosted by hospital associations and medical societies were ‘members only.'


How can non-hospital (and non-physician) providers participate in this process? Was it really the intent of CMS in having RAC provider meetings that are non-inclusive of the providers subject to RAC audits?


Although a Provider Outreach meeting was listed for Florida, and sponsored by the Florida Hospital Association, it was impossible to register at the association's Web site unless you were an employee of a Florida hospital.


Open Door Forums

Well, there was always the RAC Special Open Door Forums (ODF), with one scheduled for Part A and one for Part B in mid-April. CMS warned of limited phone capacity, and the Part A call was closed to callers nearly 15 minutes prior to the start time as reported by unsuccessful callers.


The Part B ODF seemed to have more capacity. CMS staff made presentations, and noted that the RAC representatives were on the line, but only participating as listeners. (No questions please!) During the Q & A portion there was a question from a Part A provider, who said he was only listening because he was locked out of the Part A call. CMS reassured him, stating that the same information was presented in both sessions, implying that he didn't miss anything. That seems odd, so let's check the recording of the Part A ODF that was supposed to be posted on April 16th and available for 30 days. Not there. So there is no way at this time to review the Part A call. The Part B ODF information is also missing in action from the CMS Special Open Door Forum Web site, and it should have been posted yesterday (April 22).



Non-Hospital Providers

OK, back to the drawing board! There would have to be a way for non-hospital providers to get information, or at least feel that they had the opportunity, as promised, to participate in the process.

Well, on April 20th, Pinnacle (PBSI Medicare Services), as well as other CMS contractors, published a Web site notice detailing three Provider Outreach sessions to be held on May 4-5th at the CMS regional office in San Francisco. Total capacity for the three scheduled meetings was listed at 490 participants.


These sessions were posted for ‘all providers,' including hospitals, SNF's, Rehabilitation Facilities, Home Health Agencies, DME Suppliers, and physicians. The sessions are described as an opportunity to ask CMS officials and the California RAC contractor (HealthDataInsights, Inc.) questions regarding the RAC program.


Sessions, however, were marked ‘closed' by CMS within 24 hours. Really, in California, a meeting capacity of 490 participants? Since California providers know what is coming, that meeting should have been scheduled for Candlestick Park!


Hasn't CMS got the drift that the provider community is taking this seriously? Don't they know that providers really do want to get information, and have questions answered and, at a minimum, providers want to feel that their questions are being raised, if not by them, but a provider of a like type?


Take a quick check of the updated list of Provider Outreach Sessions on the RAC Web site. It has grown to six pages, and includes new sessions, new sponsors and a new format of presenting the information. But, take a closer look: the few sessions originally listed for the ‘other' providers at the CMS Atlanta Provide Outreach, oh well poof, they have disappeared from the schedule.


Regions A, B & C now have Webinars hosted by the American Health Care Association (AHCA) designed for AHCA providers, and Region A also has a Webinar sponsored by the New England Medical Equipment Dealers Association. Maybe this was in response to the caller on the Part B ODF who asked about meetings for those closed out of the ‘members only' meetings, as she was.


An interesting note: the meeting by the Florida Hospital Association, held in March, as a meeting for "Provider Outreach" is now retroactively listed as a meeting for "hospitals." Glad that was cleared up!


This is going to be a work in progress. Notice on the latest schedule that there is a meeting designed for hospital, physicians, SNF, home health and DME providers, sponsored by the Healthcare Association of Hawaii.


Thank you HDI and CMS. Call them quick, before it disappears from the schedule. I'll see you all in Honolulu on May 8th.

 

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About the Author

Nancy Beckley is a co-founder and President of Bloomingdale Consulting Group, Inc., providing consulting services to the rehab professional. Nancy is certified in Healthcare Compliance by the Healthcare Compliance Board, and serves on the Part A and Part B Provider Outreach Education and Advisory Panel for First Coast Services Options (Florida Medicare). She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities.

She organized and conducted the rehab industry's first compliance seminar ten years ago following the OIG publication of the first compliance guidance (for hospitals).

She is the author of a current book on rehab managed care contracting: "Managed Care for Rehab Providers Made Easy: Mastering Contracts and Obtaining Fair Reimbursement."

Contact the Author: Phone: 813-654-4130 or EMail

Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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