Posts Tagged: RAC audits

Connolly Adds Nine RAC Approved Issues

RAC-LOGO-CGIThe RAC contracted for the southern and southeastern states, Connolly Healthcare, continues to post new automated issues concerning dose-versus-units-billed, further proving that injections and infusions is a major target for RAC review, and a continuing concern for provider reimbursement, especially for physicians and outpatient settings.

The List

Below are the nine new issues, posted earlier this week. Follow the links to each one, in the eduTrax RAC New Issue Database®, which can be seen with simple free registration at myedutrax.com.

Who’s Getting Stuck?

You’ve billed for it, even been paid for it. But will you get to keep the money? And you can’t take the injection back…

This is like getting an injection with a barbed needle: feels ok going in, but coming back out it hurts like <insert your favorite expletive>.

For both providers and payers, there’s no confusion about one thing: injections and infusions can be tricky to properly bill.

Instruction Available

The eduTrax® site has two excellent courses available for their paid subscribers, and these can also be purchased as downloads or CDs. Short previews are available to give you an idea of their quality and content:

BLUE-PREVIEW-ON-Button Coding Injections and Infusions — reviews the recent changes to injections and infusions codes and offers guidance on correct capture of these services. (3 minute preview)

BLUE-PREVIEW-ON-Button RAC Focus: Injections & Infusions — discusses why, how & where physicians must be involved, and addresses code selection based upon time and service provided. (8 minute preview)

Click here to send us an Email for more information or to place an order.


Still No Medical Necessity Approvals

To date, there are still no issues posted & approved for review of Medical Necessity for any issue.

As usual, we wait…

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.

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.

CGI Updates "New Issues"

Three Automated Denial Issues Added to RAC’s Site

The RAC for Region B, CGI Federal, has just this afternoon posted three new issues to their “new Issues” page. The three “new issues” approved as of 9/30/2009 are:

  1. Neulasta (billed more than once per patient per date of service)
  2. Once in a Lifetime Procedures (billed more than once per patient)
  3. Untimed Codes (specific codes billed more than one unit per date of service)

See the links above to jump to those pages. The pages now include links to Related Policy Documents.

These issues are approved for all the Region B states: Illinois, Indiana, Kentucky, Michigan, Minnesota, and Ohio.

Differences Begin to Appear

Readers should note that, to date, the CGI approved issues are all only for Outpatient Hospital and Physician claims. Other RACs have been approved for issues in both Part A and Part B claims. For example, two of the new issues have been approved for ALL types of claims for HDI in Region D, while the Neulasta issue is approved for Region D, but only for Part A claims, and with a slightly different billing rule in effect.

Furthermore, the Region C RAC, Connolly Healthcare, was already approved in June for automated review of both the “Untimed Codes” and “Once in a Lifetime” issues, for Outpatient and Physician claims, just like CGI; however, Connolly has not yet posted any approval for review of “Neulasta” claims.

The Region D RAC, HDI, was likewise already approved in June for Outpatient and Physician claims reviews for “Untimed Codes” and “Once in a Lifetime” issues, but they were also approved for “Neulasta” reviews for Part A claims only.

Details, Details

We strongly suggest that readers review these differences on the RAC New Issues pages, which can be easily accessed from the eduTrax website, HERE.

We would also remind readers that all these issues, regardless of when they were “approved” for review, the RACs can and will be reviewing claims including dates of service going back to 10/1/2007.

New Approved Issues Appear

All Four RACs Now Approved for Audits

The last of the four RACs has now posted approved issues on their websites. What this means is that all 50 states are now eligible to begin receiving RAC denials.

DCS just posted their first approved issues. Find Approved Issues listed HERE.

Watch your Remittance Advice forms for the remark code N432.

Track all the RACs

See for yourself… follow this link -> RAC New Issues Pages on myedutrax.com

First RAC Audit Issues Appear

Connolly Gets Audit Issues Approved

CMS has evidently approved the first issues for RAC audits by Connolly Healthcare. Seven specific issues are now listed on the Connolly Healthcare RAC website. Connolly is responsible for Region C, but the issues have so far only been approved for the state of South Carolina.

States Affected: South Carolina

Provider Types Affected: Outpatient Hospital and Physician.

To see the issues approved, you can visit the Connolly website.

SEE THE LIST WITH LINKS TO ALL DOCUMENT & MANUAL REFERENCES:

Visit the eduTrax website HERE.  Once on this page, choose Approved RAC Audit Issues: August 4, 2009.

What about the other RACs?

See for yourself…

DCS Healthcare (Region A)

They have a sample demand letter in Word format. They also list some documentation submission requirements. They have no issues posted, as yet.

CGI Federal (Region B)

No issues posted yet, but they do have other pages. They provider a sample demand letter from an Automated Review. They do not yet have provider contact information available, nor submission requirements.

Connolly Healthcare (Region C)

These first issues are posted to Connolly Healthcare’s website, which seems to be the most complete site, at the moment.  They have posted some sample documents for Automated Reviews and Complex Reviews, plus record submission requirements. Also, you can find a provider contact form, as well as a multi-provider contact spreadsheet for providers with multiple facilties/practices.

Health Data Insights (Region D)

Almost nothing there, so far, just a single page.

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