CMS Expands RAC Records Requests Limits

Limits Now Apply to All Institutional Claim Types, Not Just DRG Validations

The Centers for Medicare & Medicaid Services (CMS) modified its FY2010 Additional Documentation Request (ADR) Limits, expanding the scope of the rule to include all institutional providers, on January 28, 2010. Previously, the rule applied to ADRs for DRG Validation issues only, as posted by CMS on December 1, 2009, and would have only applied to Medicare Part A providers. CMS also indicated that more changes are yet to come, with rules applying to physicians and other types of providers, including DME suppliers.

The December posting indicated that there would be two “caps” made on RAC ADRs, during FY2010. Through March 2010, the cap would remain at 200 ADRs per 45 days for all providers/suppliers. However, from April through September 2010, providers/suppliers who bill in excess of 100,000 claims to Medicare, across all claims processing contractors, would have a cap of 300 ADRs per per 45 days.

These limits would apply per “campus” instead of per NPI (National Provider Identifier). The definition of a campus is CMS’s new method of calculating limits, and is based on providers’ Tax ID Numbers plus the first three numbers of the ZIP code where those provider entities are physically located.

This most recent posting does not change any of the previous limits or definitions, but does expand the rule to apply to all claim types, not just DRG Validations.

Read the new document  HERE , along with a copy of the text from the December document.

Region B RAC Approved for 47 New DRGs

CGI Federal Lists 20 New Issues

Includes 47 DRGs for Overpayment and 4 DRGs for Underpayment

CGI Federal, the RAC for Region B (western states), posted 20 new approved issues for review on their RAC Issues page, on Friday, January 22, 2010. Following the format being used by the Region D RAC, HDI, the listed issues are grouped together by Issue Name, which often includes multiple MS-DRGs.

All of the new issues are approved for DRG Validation, affecting all seven of the Region B states (IL, IN, KY, MI, MN, OH, WI). Notably, one of the new issues posted is approved for underpayment review, although only for four(4) of the five (5)  MS-DRGs listed in the issue approved for overpayment review.

None of the new issues mention review of Medical Necessity, although such reviews do not appear to have been approved for any of the RACs, to date. However, it is likely that the existing DRG Validation issues will all be approved for medical necessity review in short order, since the CMS RAC Review Phase-In Strategy allows for such approvals in calendar 2010.

Find links to all the RAC New Issues Pages here. For more useful lists, see below.

Use the links below to see details, in our database:

1 MSDRGs 189: Acute Respiratory Failure
2 MSDRGs 222, 224, 226: Cardiac Defib Implant W Cardiac Cath W/O AMI/HF/Shock W MCC
3 MSDRGs 216, 217, 219, 220: Cardiac Valve & Oth Maj Cardiothoracic Procedures w CC or MCC
4 MSDRGs 034, 035, 037, 038: Carotid Artery Stent & Extracranial Procedures w CC or MCC
5 MSDRGs 231, 233, 235: Coronary Bypass W PTCA/Cardiac Cath w MCC
6 MSDRGs 131: Cranial/Facial Procedures w CC or MCC
7 MSDRGs 020, 021, 023, 025, 026: Craniotomy, Endovascular and Intracranial Vascular Procedures w CC or MCC
8 MSDRGs 113, 116, 121, 124: Disorders Of The Eye, Infections And Procedures (Orbital And Interocular) w CC or MCC
9 MSDRGs 689: Kidney & Urinary Tract Infections w/MCC
10 MSDRGs 237: Major Cardiovasc Thoracic Aortic Aneurysm Repair Procedures w CC or MCC
11 MSDRGs 163, 164: Major Chest Procedures w CC or MCC
12 MSDRGs 129: Major Head & Neck Procedures w CC or MCC
13 MSDRGs 228, 229: Other Cardiothoracic Procedures w CC or MCC
14 MSDRGs 133: Other Ear, Nose, Mouth & Throat O.R.Procedures w CC or MCC
15 MSDRGs 246, 248, 250: Perc Cardiovasc Proc W Drug-Eluting Or Non Drug Eluting Stent w MCC or 4+ Vessels/Stents
16 MSDRGs 041, 042: Periph/Cranial Nerve & Other Nerv Syst Proc w CC or MCC
17 MSDRGs 028, 029: Spinal Procedures Neurostimulators W CC or MCC
18 MSDRGs 003, 004, 011, 012, 013: Tracheostomy
19 MSDRGs 004, 011, 012, 013: Tracheostomy – Underpayment
20 MSDRGs 031, 032: Ventricular Shunt Procedures W CC or MCC

Find a list of all their posted issues HERE.  (Registration required.)

RACs Add New Issues

All Four RACs Now Approved for Complex Reviews

Three of the four CMS Recovery Audit Contractors (RACs) have posted new issues this past week. All four RACs have now posted their first Complex Review issues — all for DRG coding and DRG Validation.

No issues have been posted yet to include review of Medical Necessity. However, since DRG Validation, by CMS’s own definition, seems to include review of medical necessity, there is little doubt that these issues will all be released by CMS for Medical Necessity review in short order.

Find links to all the RAC New Issues Pages here. For more useful lists, see below.

RAC Region A — DCS Healthcare

Besides some minor changes to wording, DCS has not made many new posts. This week, however, they posted three new issues including 10 DRGs (plus 2 that are listed twice: 003 and 004). Use the links below to see details, in our database.

Find a list of all their posted issues HERE.  (Registration required.)

RAC Region B — CGI Federal

On Tuesday, January 19, CGI posted 15 new issues including 45 DRGs . Use the links below to see details, in our database.

Find a list of all their posted issues HERE.  (Registration required.)

RAC Region C — Connolly Healthcare

Connolly has made no significant changes to their lists since 12/31/2009, when they posted the first Complex Review issues for any RAC. However, the year is young.

Find a list of all their posted issues HERE.  (Registration required.)

RAC Region D — Health Data Insights or HDI

After posting nearly all the DRGs for review on January 7 (they posted well over 500 of the 746 that exist), HDI may be out of new complex issues for a while. Nevertheless, they did post two new Automatic Review issues:

Find a list of all their posted issues HERE.  (Registration required.)

Conducting Internal DRG Validations

Why wait for the RAC to begin sending Records Requests? Providers can perform their own DRG Validations and head off future issues — eduTrax and RAC University just conducted a complete webinar on the subject, providing a template and multiple examples of exactly how to do just that. See how to order “Dissecting a DRG like a RAC: Do-It-Yourself DRG Validation” online or on CD, HERE.

Coming Soon:

Download our Database of RAC Approved Issues

The RACs have to post all their new approved issues for review on their public websites. How they post them, however, is not defined, and consequently, each one has created their own format. These formats, however, are not “provider friendly” and tend to make it difficult to track what’s new and/or changed, day to day.

To keep up, we created our own database of all the posted issues, and we update as new issues are published by the RACs. We recently made it available for all our registered users, and have received many requests to make the database available for download. Of course, a provider would need to keep downloading it, whenever there are updates, but having it available in a reasonable format is helpful to many of our readers.

Soon then, eduTrax will make our complete database of RAC New Issues available for download as CSV files (a convenient format for use in Excel or other spreadsheets). The database includes search and sort capabilities, and includes all the RAC provided data, plus all the CMS provided data that coding and compliance experts need, such as MSDRG description, Relative Weight, Transfer DRGs, Special Pay DRGs, GLOS and ALOS, FY09 Rank (by number of discharges nationwide), and a v24-to-v27 Crosswalk for the older DRG codes.

New Issues for RAC Region B

Two New Issues for Automated Review Posted — Still No Complex

Oxaliplatin billings and Clinical Social Workers (CSW) services are now approved issues for CGI, the RAC for Region B, covering the upper midwestern states. These two new issues were posted after 5pm PT on Tuesday, January 13.

Neither Region B nor Region A has yet to be alerted to any issues approved for Complex Review, although the RACs for Regions C and D have posted over 560 DRG Validation issues approved for review by CMS.

The pattern of when issues are posted by the RACs is still haphazard. According to their posts, the Oxaliplatin issue was approved by CMS on 12/22/2009, while the CSW issue was approved (for Region B, anyway) on 1/5/2010.

The CSW issue posting marks the fastest turn-around seen to-date, for an approved issue being posted — just one week.

To see the complete list of New Issues, register and logon to the eduTrax RAC New Issues Tools®.

Ambulance Services Reviews Posted by Another RAC

A Different Posting to Review Ambulance Services during Inpatient Stays

CGI, Region B RAC for CMS, posted Automated Reviews of Ambulance services, as follows:

Separately Paid Ambulance Service during Inpatient Hospitalization Review — Affects Outpatient & Professionals

The description listed is:

Ambulance transports provided by Hospital-Based Ambulance Providers and Suppliers to beneficiaries who are in an inpatient stay are the responsibility of the inpatient hospital provider with the exception of transports on the day of admission, day of discharge and during a leave of absence from the inpatient facility.

This is a different issue from the one just posted by the Region A RAC. That issue only reviewed claims by Ambulance Service Providers, where this new posting reviews Outpatient and “Professional” claims.

To see the complete list, register and logon to the eduTrax RAC New Issues Tools®.

RAC A Posts New Issue: Ambulance Services

Ambulance Providers Now Being Reviewed

Diversified Collection Services (DCS), posted the following new issue on January 7, 2010:

Ambulance Unbundled Services During an Inpatient Hospital Stay — affects Ambulance Providers, Automated Review.

The description states:

Ambulance services should be billed to the inpatient provider for services for inpatients. Therefore, an issue may exist when a beneficiary received ambulance services during an inpatient stay, which have been billed and reimbursed under Medicare Part B.

Also, during December, DCS posted these seven (7) new issues:

  • Headrest with a Power Operated Vehicle or a Power Wheelchair with a Captain’s Chair Seat
  • Lower Limb Suction Valve Prosthesis
  • Multiple DME Rentals within a Month
  • Prosthetic Additions with Initial or Preparatory Knee Prosthesis
  • Solid Insert with Seat or Back Wheelchair Cushions
  • Wheel Attachment with New Non-Wheeled Walker
  • Clinical Social Worker (CSW) Services

To see the complete list, register and logon to the eduTrax RAC New Issues Tools®.

RAC Adds ‘New Patient’ Reviews

Region D RAC Adds Six, Aims at Physician Practices

About 9pm ET, Thursday, January 7, Health Data Insights was busy again, adding six (6) more new approved issues to their RAC Approved Issues page. Go see for yourself here, or here’s just a list of them:

  • CSW During Inpatient — Automated Reviews, Part B claims for services rendered during an Inpatient stay.
  • DME while in Hospice — Automated Reviews, DME claims related to terminal Dx, during Hospice period.
  • NCCI Edits — Automated, Part B, certain code combinations with modifier indicators 0 or 1.
  • Hospice Related Services — Automated Reviews, Part A & B claims related to terminal Dx, during Hospice period.
  • Technical Component of Radiology — Automated Reviews, Part B claims, not payable in IP or OP.
  • Not a New Patient — Automated Reviews, Part B claims, New Patient CPT codes for patients with face-to-face visits in previous 3 years.

Remember, the RACs have to submit justification to CMS in order to “reopen” all these claims for review. So, we can expect that they must already have plenty of “targets” in mind.

That last one is squarely aimed, of course, at Physician Practices.

Where 66 is more than 500

If we were playing Jeopardy, the correct answer would be:

What is the HDI RAC New Issues page?

We reported yesterday that the CMS RAC for Region D, charged with auditing healthcare providers in the western US, posted 66 new DRG Validation issues on their website.

We were in error. Well, only if you want to count the number of DRGs in their “issues.”

By our count, the number is really 530 DRG Validation issues.

Hey, even if we counted wrong (and we’re checking our math, as we enter all the issues into our RAC New Issues Database), if the true number is only 430, at least we’re not being disingenuous.

Why would a RAC list more than one DRG in an issue? Why, indeed. Such a list is at least not helpful.

Stay tuned for the next post… We’ll list some things you need to consider, as a provider… even now, before you start getting records requests…

66 New Issues Posted for RAC Region D

At 2pm PT on January 6, 2010, Health Data Insights posted a new approved issue for review:

Anesthesia Care Package E&M Services — Automated Review, Part B providers, in all states in Region D.

But Wait! There’s More!

At 3:30pm PT, they followed up with 66 (count ‘em) new DRG Validation issues.

We are currently creating a list of them, and conducting some analysis…

First thing we noticed: half of the 66 DRG Validation issues are for UNDERPAYMENTS. This marks the first time any RAC has posted an issue for underpayments, under the permanent program.

Second thing: each “issue” as posted includes MULTIPLE DRG Groups. For example, the first issue in their list is entitled, “DRG Validation-Amputations.” There is no such DRG or MS-DRG. “Amputations” covers several body areas, and therefore would involve several MDC Groups — 3 in fact.

  • MS-DRG 616 – Amputat Of Lower Limb For Endocrine,Nutrit,& Metabol Dis with MCC
  • MS-DRG 617 – Amputat Of Lower Limb For Endocrine,Nutrit,& Metabol Dis with CC
  • MS-DRG 618 – Amputat Of Lower Limb For Endocrine,Nutrit,& Metabol Dis without CC/MCC

Grand total = 12 DRGs in one issue. And that’s not even the record!

Further down the list is DRG Validation – Cardiac Procedures. Grand total in that “one issue” is 29 DRGs.

NEXT down the list is Cardiovascular Diseases 31 DRGs.

Further… Gastrointestinal Disorders. Someone decided to just list RANGES: 368 thru 395 and 432 thru 446. Grand total: a mere 28.

Gastrointestinal Procedures, however… they just list ranges again: 326 thru 358, 405 thru 415, 417 thru 425. Grand total: 53 DRGs. In one issue…

What ’s the final count? We’ll total it all up tonight and tell you tomorrow. Meanwhile, we have a lot to put into our database.

See all details on their page.

All the new issues are being broken up into separate DRGs (triplets or doublets where appropriate) and added to the eduTrax RAC New Issues database, as this is being written… Check the database tomorrow!

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Connolly Posts Over 40 New Issues

Connolly Healthcare, Region C RAC, posted over 40 new issues, all for Complex Reviews, most for Inpatient Hospitals, during the final week of December, 2009. Happy New Year! The total number of issues now approved for Connolly’s review is over 75. Most of those issues will review MS-DRG coding and DRG Validation, but those all include the following phrase in their title:

At this time, Medical Necessity excluded from review.

Of course, this could change at any time now, since CMS plans to allow Medical Necessity to be reviewed, beginning in calendar 2010. (See CMS RAC Review Phase-in Strategy)

Non-User Friendly Lists

However, as we discovered in this past quarter, since the RACs began posting new issues, as they are required to do by CMS, we noticed that the WAY in which they post the new issues is not consistent, from RAC to RAC. What’s worse, there seems to be no effort on the part of the RAC to make that information easy to sort, copy, or deal with in any useful form. That is, you can’t sort the list, you can’t make a decent copy of it, you can’t even see all the data you might like to know on each issue.

Changes Made Without Notice

The worst part, however, is the way that the RACs do their postings: willy-nilly. In other words, they just throw the posts up there. There is no notice sent or made about a new post being added and/or changed. When new issues are added, there is also no effort made to group similar issues together. For example, on the Connolly list, some of the DRG Validation issues involve all three of an MS-DRG triplet (a triplet is an MS-DRG “group,” if you will, a set of three MS-DRGs that represent all three severity levels assigned by CMS to that diagnosis — e.g., Pneumonia is assigned a triplet, 193/194/195, representing Pnuemonia with an MCC, with just a CC, or without MCC or CC). This is not huge, but it certainly makes it difficult to work with the list.

Needless Complexity

For example, we know of one hospital in Region C that received a single letter requesting 24 medical records, one for each of 24 different MS-DRGs. The MS-DRGs were simply listed by number, with no descriptions. For a coding department, this is not a huge problem. However, for a RAC Team, it is an issue. Why? Because the letter probably has to travel thru several hands to get to the Coding department, who then have to look up the codes, add the descriptions, and then send the letter back up the path to all concerned parties, so that they know what they’re doing.

How much time did that just add to the time it takes to identify, find, copy and send off those records to the RAC? Providers are already under the gun to get the records back to the RAC, and this makes the process all that much more difficult. And needlessly!

A New Way to See the New Issues

For our own internal use, eduTrax developed it’s own database of the new issues, and we are pleased to now make that database available to providers, for their use.

The RAC News Issues Page provides direct links to the four RAC websites. You need not register or login to see these links. Simply go HERE, and choose one of the RAC links.

The RAC New Issues Menu requires you to register, which is free and takes only a minute to do. (You will have to confirm your email address, as a security measure.) Once you login to the site, select the RAC New Issues Page, and a new menu will appear on your left. (preview here)

eduTrax® RAC New Issues Alert Services

This new service now gives you the following choices:

  • See New Issues by each RAC — but in a list that is sortable and searchable,
  • See New Issues by State — click your state, get a list of the issues approved for that state.

We keep the database updated daily. Currently, we are changing the Issue Title, in our database, so that it is more friendly. For example, we put the MS-DRG number at the front of the title. This makes it easier to search and sort.

To search for an MS-DRG, simply enter the number alone in the Title Search field, then hit Go.

To sort any list by title, simply click on “Issue Title” at the top of the list.

Go HERE to see some instructions on using the sort and search filters.

Soon, we will announce an eMail Alert Service — you get an email from us whenever a RAC posts or changes an issue, and the email will include what got added and/or changed. That way, you stay alerted, and you don’t have to figure out what changed — we do it for you!

More Coming Soon…

So, we recommend you go look at the lists yourself. And watch for the announcement about our new Alerts services.

Also, our next post will include some analysis of the new issues, and what you need to be looking for.

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