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CMS releases RAC provider outreach schedule
CMS’ RAC provider outreach has begun, according to the schedule posted March 19 on the CMS Web site. Outreach began earlier this week in multiple regions and is scheduled through the end of May, according to the schedule. CMS will update the schedule as it adds additional outreach sessions.
Click here to view the outreach schedule.
Breaking News: CMS Releases Updated RAC Expansion Schedule
BREAKING NEWS FROM HCPRO
By Andrea Kraynak, CPC-A
CMS has revised its RAC expansion schedule, according to the new “RAC Phase In Map” posted February 10 to the CMS Web site. The first phase is set to begin March 1, 2009. The second stage will begin August 1, according to the map.
The prior expansion schedule was set to occur in three stages, however, the now-resolved protests by the unsuccessful contract bidders Viant, Inc., and PRG Schultz, USA, Inc. delayed the initial onset of the permanent RAC program.
“For those hospitals who have a couple of weeks to prepare, I believe one of the biggest challenges is to have well established coordination of denials and appeals and an effective tracking tool,” says Yvonne Focke, RN, BSN, MBA, revenue cycle director at St. Elizabeth and St. Luke Hospitals in Covington, KY. “For those of us who have until August, we’ll have to continue on course with our RAC preparedness, including assessing our gaps, quantifying our risk and establishing a tracking mechanism.”
Editor’s note: To view the updated expansion schedule, visit the CMS Web site. For more general information on the Medicare RAC program, visit www.cms.hhs.gov/rac.
RAC Protest Resolved: CMS to Continue Implementation
BREAKING NEWS FROM HCPRO
Stop work order lifted, implementation again underway
By Andrea Kraynak, CPC-A
CMS announced February 6 the permanent RAC program is once again underway as the RAC bid protests filed by Viant, Inc., and PRG Schultz, USA, Inc. have been withdrawn. Viant and PRG’s protests were resolved February 4, which means the stop work order has been lifted, according to CMS.
The Government Accountability Office (GAO) had 100 days to issue a decision after the unsuccessful bidders filed their protests November 4, 2008. The GAO had been set to render a decision on the protests on February 9 for Viant, and February 11, for PRG Shultz.
The RACs by jurisdiction are as follows:
- Region A: Diversified Collection Services
- Region B: CGI Technologies and Solutions
- Region C: Connolly Consulting, Inc.
- Region D: HealthDataInsights, Inc.
“If you have put your RAC preparation on hold, it’s time to start finalizing your strategy. And it’s time to become familiar with the contractor in your area,” according to Kimberly Anderwood Hoy, JD, CPC, is the director of Medicare and compliance for HCPro, Inc.
As a result of the protest settlements, these RACs will be subcontracting with PRG-Schultz and Viant. (PRG-Schultz will work with Diversified Collection Services in Region A, CGI in region B, and HealthDataInsights in Region D. Viant Payment Systems will work with Connolly Consulting in Region C.) PRG-Schultz and Viant will have different responsibilities—including possible claim review—in the various regions.
Editor’s note: To view this information on the GAO Web site, visit www.gao.gov/decision/docket and enter file #400443. For additional details from CMS, visit their Web site at www.cms.hhs.gov/RAC.
Breaking news: RAC protests withdrawn
The RAC bid protests filed by Viant, Inc., and PRG Schultz, USA, Inc. have been withdrawn, the Government Accountability Office (GAO) Web site is reporting February 6. To view this information on the GAO Web site, visit www.gao.gov/decision/docket and enter file #400443.
The GAO had 100 days to issue a decision after the unsuccessful bidders filed their protests November 4, 2008. This means that a decision would have been due early this month. The GAO had been set to render a decision on the protests on February 9 for Viant, and February 11, for PRG Shultz.
ICD-10-CM/PCS: Start preparing, but be flexible
By Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, Inc.
Last week, HHS announced October 1, 2013, as the final implementation date for ICD-10-CM/PCS. ICD-10 was adopted for all diagnosis coding and for inpatient procedure coding. Also adopted were the standards changing the electronic claim format to accommodate the expanded ICD-10 codes.
For providers who have not begun preparing for ICD-10, this is a wake up call to start preparations. Not only will coders need to be retrained in the new coding system, but many other systems will have to be updated to accommodate this change. Providers will need to work with virtually all of their software vendors to implement this change. One of the most difficult parts of the transition, as we have experienced with the NPI, is not our own preparations, but awaiting CMS guidance on changes to their systems and policies.
For example, systems for identifying services that may not be medically necessary, triggering an ABN, are dependent on the ICD-9-CM codes in Medicare’s current policies. These systems, forms, and related items will have to be updated to ICD-10 codes when updated policies are available from Medicare and its contractors. However, updating medical necessity policies may not be at the top of CMS’s list for preparation for ICD-10, considering the number of other things in Medicare systems that have to be updated. Hospitals may have to wait until just before or even after the implementation date for the ICD-10 medical necessity policies to be updated, delaying the hospital’s implementation.
In some ways, CMS’s preparation for ICD-10 will be more extensive than for providers. The entire Inpatient Prospective Payment System (IPPS) is built on the ICD-9-CM codes, which will have to be transitioned to ICD-10. Additionally, CMS will have to have enough data from ICD-10 coded claims to set rates for the IPPS system, generally two years’ worth. This may mean that, for a time, providers will have to report more than one set of codes: ICD-9 for calculation of their payment, and ICD-10 for data collection and future rate setting.
Hospitals should make a work plan to deal with ICD-10, but their plan will have to build in significant flexibility, as the time frames will often be dictated by when CMS guidance and policy information becomes available. Hospitals may even need to be prepared to run parallel systems for ICD-9 and ICD-10, as they currently do now for National Drug Codes, which CMS has not adopted, but which have been adopted by most other payers for reporting hospital drugs. Hospitals will have to monitor CMS’s implementation efforts carefully over the next few years and prepare for contingency plans when guidance and policy information from CMS is delayed.
HHS announces final timeline for transition to ICD-10-CM
BREAKING NEWS FROM HCPRO
HHS announces final timeline for transition to ICD-10-CM
Regulation names October 1, 2013 as implementation date
The Department of Health and Human Services (HHS) announced on January 15 the final regulation to replace the ICD-9-CM code sets now used to report healthcare diagnoses and inpatient procedures with the more advanced ICD-10-CM code set currently used in other nations. The final regulation will implement the ICD-10-CM code set two years later than HHS initially proposed: October 1, 2013.
The new timeline comes as welcome news to the industry, which feared that the original proposed 2011 implementation date wouldn’t give organizations enough time to prepare for the change.
Gloryanne Bryant, BS, RHIA, RHIT, CCS, senior director of coding and health information management (HIM) compliance for Catholic Healthcare West (CHW) in San Francisco, says CHW’s recommendation was that an implementation date should have “at least three complete years, and because the implementation date would come out in January, we would foresee that moving [implementation] ahead would make more sense for everybody. So I’m pleased with the dates in the final rule.”
Dan Rode, MBA, CHPS, FHFMA, vice president of policy and government relations for The American Health Information Management Association (AHIMA) in Washington, DC, agrees. “It certainly gives people plenty of time to implement and do the testing. On the other hand, it’s not a reason to think that we can sit by for a while until we get closer to 2013. The concerns that we’ve raised about what has to be done over the next few years are still in front of us.”
“We’ve got an extra year, so let’s use it wisely,” he says.
The delay in implementation did cause some mixed feelings. Jennifer Avery, CCS, CPC-H, regulatory specialist with HCPro, Inc. in Marblehead, MA, admitted to some excitement over the proposed 2011 date. “I’m sad in a way,” she says. “This gives us a little more time to prepare. At the same time, I can’t see why prolonging it will make it any better.”
Nearly 30 years old, ICD-9-CM will run out of possible code combinations within a year. The present code set includes 17,000 codes, while ICD-10-CM includes more than 155,000 possible code combinations. This greater number of combinations allows ICD-10-CM to expand and keep up with new diagnoses and inpatient procedures. The United States is virtually the last industrialized country to adopt ICD-10-CM, according to a statement on the AHIMA Web site.
A second final rule issued concurrently with the ICD-10-CM final rule states the pending adoption of the X12 data standard, Version 5010, which includes updated standards for claims, remittance advice, eligibility inquiries, referral authorizations, and other administrative transactions that will take effect January 1, 2012. The current X12 standard, Version 4010/4010A1, cannot accommodate the use of ICD-10-CM code sets, making this change crucial. The second final rule also references Version D.0 for pharmacy transactions and NCPDP Version 3.0, a standard for the Medicaid pharmacy subrogation transaction.
Small health plans have an additional year to adopt 5010 and must be compliant with Version 3.0 by January 1, 2013.
According to the CMS press release, both regulations will be published on January 16. To view them when published, go to www.gpoaccess.gov/fr/browse.html. Click “Go” next to 2009.
HIM directors: Need help dealing with RACs?
RACs will present a very significant challenge for hospitals and HIM directors will need to respond quickly when Medicare notifies them of suspected overpayments.
Luckily, noted expert Jean S. Clark, RHIA, has teamed up with HCPro, Inc., to publish The HIM Director’s Guide to Recovery Audit Contractors, a helpful guide for HIM directors who need help handling RACs. In the book, Clark covers:
- Department roles and the RAC team
- Internal management of a RAC request
- Management of appeals
With thoughtful preparation, strong internal processes, and an educated and ready RAC team in place, HIM directors can improve their hospital’s chances of successfully appealing denials. The HIM Director’s Guide to Recovery Audit Contractors is your first line of defense.
Revenue Cycle Institute releases new and updated white papers
The Revenue Cycle Institute announces new and updated white papers available for download. In addition to a new white paper on physician queries by Shannon McCall RHIA, CCS, CCS-P, CPC-I, director of coding and Health Information Management for HCPro, Inc., you will find an updated version of the whitepapers on the RAC demonstration project and the new ABN by Kimberly Anderwood Hoy, JD, CPC, director of Medicare and Compliance at HCPro, Inc., on the Revenue Cycle Institute Web site (www.revenuecycleinstitute.com).
To download white papers, click here.
