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.
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