Every year the Centers for Medicare and Medicaid Services (“CMS”) evaluates concerns raised by providers about the Recovery Audit Program (“Program”) and issues numerous changes to the Program. On December 31, 2014, CMS issued its Recovery Audit Program Improvements for 2015, which took effect beginning with each new contract awarded to Recovery Audit Contactors (“RACs”) on December 30, 2014. The improvements for 2015 apply to RACs involved with the recoupment of Medicare payments from providers across all facility types, including hospitals.
Providers should expect several beneficial changes to the Program once the RACs obtain their contracts and begin their audits. These improvements are categorized into three initiatives: (1) reducing provider burden; (2) enhancing CMS oversight; and (3) increasing Program transparency. Each of these initiatives addresses some but not all of providers’ concerns over the recent years. So what can providers expect?
Some of the improvements are discussed in more detail below, most notably being the reduction in the period in which the RACs can reach back and deny claims based on patient status. Previously the RACs could deny claims going back three years from the date of service, but now CMS will limit the RACs to a six-month look-back period for claims filed by the hospital within three months of the date of service. One important thing to remember, however, is that these “improvements” are changes to the RACs’ contracts with CMS and will not necessarily become regulations or law. In other words, providers must rely on CMS to enforce its contracts. Here are the most notable changes.
Reducing Provider Burden
Enhancing CMS Oversight
Increasing Program Transparency
If you have any questions regarding this Monthly RAC Report, please contact Larry McCarty (firstname.lastname@example.org) or Jeff Moore (email@example.com).