Implementation of permanent and nationwide RAC Program

Now that CMS has implemented a permanent and nationwide Recovery Audit Contractor (RAC) Program, as authorized by the Tax Relief and Healthcare Act of 2006, hospitals need to keep themselves informed about the issues that have been approved for review in their region. Going forward, the four regional RACs will continue to review claims on a post-payment basis, using standard Medicare policies. They will be limited, however, to a three-year look-back period, with no review of claims paid prior to October 1, 2007.

In addition, they must submit issues for approval by CMS, prior to widespread review. Each RAC is required to post on its Web site a list of those issues that have been approved for review. The list of approved issues is continually being updated, so hospitals need to check for any changes or additions on a regular basis.

For example, CGI, the RAC for Region B (which includes states in the Midwest and Upper Midwest) recently updated the issues approved for review to include the following:

• Blood transfusions (outpatient hospital and physician)—IN, MI, MN
• IV hydration (outpatient hospital and physician)—IN, MI, MN
• Bronchoscopy services (outpatient hospital and physician)—IN, MI, MN
• Neulasta (outpatient hospital and physician)—IL, IN, KY, MI, MN, OH, WI
• Once-in-a-lifetime procedures (outpatient hospital and physician)—IL, IN, KY, MI, MN, OH, WI
• Untimed codes (outpatient hospital and physician)—IL, IN, KY, MI, MN, OH, WI

Contact information for the four regional RACs is set out below:

• Region A (Mid-Atlantic and New England) — Diversified Collection Services
• Region B (Midwest and Upper Midwest) — CGI
• Region C (South and Southeast) — Connolly Consulting
• Region D (West and U.S. Territories of Guam, American Samoa and Northern Marianas) — HealthDataInsights

Additional information can also be found on the CMS RAC Web site. Hospitals should incorporate a review of all identified issues into their internal improvement and compliance efforts.