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Wysłany: Wto 11:23, 22 Mar 2011 Temat postu: ben hogan - physician managed care contracts |
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Preparing For The Medicare Rac Audits | A Business Article
Due to the success of the Recovery Audit Contractor (RAC) demonstration CMS now plans to recoup more monies as the permanent RAC is rolled out to all states by 2010.
Now is the time to prepare for increased scrutiny of your Medicare claims; the RAC's will be in your state soon, if they are not already there.
The Department of Health and Human Services and Office of Inspector General provide a model compliance program to provide healthcare providers with guidance to prepare for the RAC. The seven elements of a model compliance program are as follows:
-Designation of a compliance officer and compliance committee
-Development of compliance policies and procedures
-Establishment of open lines of communication
-Appropriate training and education
-Internal monitoring and auditing of claims
-Response and corrective action to detected deficiencies
-Enforcement of disciplinary actions
In today's health care environment most entities are already burdened with the every day challenge of accurate billing and coding, compliant documentation,[link widoczny dla zalogowanych], HIPAA, physician managed care contracts, Stark laws, vendor contracts, and most importantly, patient service.
This leaves most health care entities with fewer resources to focus on compliance and audit issues.
With that being said, how does one go about dealing with the increased burden of potential RAC audits?
Your initial step should be to perform an internal audit review of your organization's documentation and compliance procedures. We know that based on Demonstration Project results that CMS posted that somewhere between 70% - 75% of overpayments identified were from coding errors and lack of documentation to support medical necessity. With that being said it would make sense that your organization focus its attention and resources in these areas.
For your coding accuracy and medical necessity review,[link widoczny dla zalogowanych], it is critical to perform a "base line review" to evaluate your organizations compliance with the rules and regulations. The review will help you identify deficiencies and correct them (including issuing refunds) prior to the RAC auditors showing up. It is also critical that you implement an education plan based on your findings for your staff and medical providers. If your practice gets in the habit of performing a review,[link widoczny dla zalogowanych], identifying errors and providing education, you will notice that your error rates will drop significantly.
In terms of your internal review, there are many things to consider. Does your organization have the internal expertise to decide what areas to focus on? Will you base your efforts on the RAC findings to direct your focus on cases to validate medical necessity and proper coding? There are many variables that need to be pre-determined if your organization opts to do an internal audit review.
You will need to determine how many charts to review, whether this number is a calculated number that is representative of your annual billings or just a random sample. These are just a few of the questions that will need to be answered before your organization moves forward with an internal audit review.
One thing that every facility needs to think about that is considering doing internal audits is that you must be confident that your audits are being performed by individuals who are "independent". In addition it is critical that your audit team have the appropriate skill set and credentials to be conducting the audits. For those that do not have the resources to conduct audits internally,[link widoczny dla zalogowanych], consideration should be given to hiring a third party audit firm that has the experience and credentials to assist your organization with the internal audit function. When selecting a vendor, make sure you are engaging a firm that has RAC experience and the appropriate credentials of clinical auditors to ensure that they will give you the service and skill set you need. It is critical that your audit results can support any findings against the RAC just in case any audit issues arise.
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