Posts Tagged: medical records request limits

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.

Open Door Forums to be Posted

CMS continued its efforts last week to educate healthcare providers on the permanent Recovery Audit Contractor program with two Open Door Forum calls. The following points were discussed during one of the calls:

Record Request Limits: Record Request Limits are evidently to be based on group NPIs, not the number of NPIs assigned to individual physicians. (find the official document here) This may be good news, or it may not, depending on your setup. For example, a group of 18 physicians might have 2 NPIs, if they are setup in two locations, with 9 MDs in each. The rule states that a group NPI (with 6-15 MDs/group) has a limit of 30 records every 45 days. So, the two groups together could get requests for 60 records every 45 days. However, if there are 3 NPIs, with 6 MDs in each of 3 groups, then there could requests for up to 90 records every 45 days.

Line-item billing: For a claim containing multiple CPT codes for the same date of service, each code (i.e., procedure) constitutes an item that RACs can review. Many providers consider an encounter or visit as a single claim for that patient for a date of service, even if it includes several CPT codes.

Contingency fees: RACs receive the same contingency fee regardless of whether they identify overpayments or underpayments. However, keep in mind that during the demonstration project, the number of overpayments found FAR exceeded the number of underpayments found. Let’s not hold our breath waiting for underpayments to be found by a RAC.

Electronic Submissions: Per the call, the RACs are not prepared to receive electronic data interchange now, and will not be for quite some time. For now, providers should submit paper claims (via fax) or send images of electronic medical records via CD or DVD.

Recordings/Transcripts Promised

CMS has promised to make recordings of both calls available on the CMS Open Door Forum Web site. If past history is any guide, these will probably be transcripts, instead of audio recordings. However, at the moment, the due dates have passed and no recordings are yet available, at the time of this writing. We will post a notice here, on the blog, when the “recordings” do become available.

Outreach Schedule Updated

CMS’ recently updated their RAC education and outreach schedule — you should check it for information on sessions coming to a city near you. The schedule includes information regarding which providers (e.g., hospitals, physicians, etc.) should attend the sessions. CMS plans to update the RAC schedule as new sessions become available.

Providers in a yellow or green state have sessions scheduled in various cities, soon.

If you are in a yellow or green state, and believe CMS has no outreach sessions for your type of provider scheduled in your area, we highly recommend that you e-mail CMS to inform them and request more sessions.

Providers in a blue state have outreach sessions scheduled beginning in August. If you do not see any sessions scheduled near you, keep checking back, as more will likely be scheduled before August.

Get All New Posts by eMail

Enter your email address:

Delivered by FeedBurner

post categories

Clicky Web Analytics

Weblogs Directory

Powered by FeedBurner

 Subscribe in your own
Favorite RSS Reader

Pageviews in 2010 =