Posts Tagged: medical records review process

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.

CMS Modifies The FFS Medical Review Process for FY2010

The vast majority of Medicaid errors are due to inadequate documentation…” – CMS

The above statement comes directly from a Fact Sheet just posted on the CMS website. (Find the sheet here.) Candidly, we know this is not really NEW. It is a rather aged refrain. Nevertheless, we think it stands reporting/repeating, because it does seem to keep coming up, and this is just the latest, most public declaration of what is really at issue, and further substantiates what was even reported during the RAC Demonstration Project.

What is “news” is this statement in the Fact Sheet:

Based on recommendations from the HHS Office of the Inspector General (OIG), Members of Congress and CMS clinical experts, the Agency modified the FFS medical review process used to identify improper payments this year.

There is no explanation of what or how they changed the review process, but the results are quite impressive:

As a result of this heightened scrutiny and more complete accounting of Medicare FFS claims, CMS is reporting a 2009 FFS error rate of 7.8 percent, or $24.1 billion, compared to 3.6 percent in 2008.

The calculated error rate more than doubled, between 2008 and 2009. One can readily deduce that the changes, whatever they are, are significant.

The changes are neither listed nor detailed, but CMS does state that it is “taking further steps” to insure the following:

  • that providers are submitting all required clinical and medical documents to support a claim,
  • that providers’ signatures on medical documents are legible,
  • that a provider’s claims history can no longer be used to fill in missing treatment documentation, and
  • will require that medical information from a provider be included to support DME claims, in addition to the already required records from suppliers.

All of those steps are significant. While CMS again neither mentions nor details what these “further steps” are, it behooves a provider to pay attention to what they have outlined as their intended targets — namely, the four bullets, above.

It is also interesting to note that while much of the industry is focused on what the RACs are doing, the RACs were not even mentioned in this report, but HEAT was directly named. If you are not aware of HEAT, you should see our previous post about them.

See our news article about CMS’ Press Release and the Fact Sheet, here.

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