Medicare to Intensify Audits in all 50 States
The Centers for Medicare & Medicaid Services (CMS) recently confirmed that the Recovery Audit Contractors (RACs) will operate in all 50 states by the end of this year. RACs identify over payments and under payments by CMS to Medicare providers.
The RAC program evolved from the three-year RAC demonstration project stipulated by the Medicare Modernization Act (MMA) of 2003. The Tax Relief and Health Care Act (TRHCA) of 2006 made the RAC program permanent and authorized CMS to expand it to all 50 states by 2010. The permanent RAC program limits the medical record review period to three years and prohibits audits on claims paid before Oct. 1, 2007. The program requires RACs to have a physician medical director and certified coders available to discuss denials with providers. CMS also announced the number of medical records RACs may request per National Provider Identifier (NPI) for 2009. CMS will likely adjust these limits each year.
Medical Record Limits for 2009 are:
- 10 medical records per 45-day period for solo practitioners;
- 20 medical records per 45-day period for 2 to 5 provider offices;
- 30 medical records per 45-day period for groups of 6 to 15 providers; and
- 50 medical records per 45-day period for groups of 16 or more providers.
Every group should start preparing a plan to deal with these audits. The old saying is “failure to plan, is a plan to fail”. Groups will need to develop a system for documenting each record request and track the audit of each claim to completion. As with any audit, if your group can’t provide the documentation of the services rendered, it is as if the service was never rendered. I have provided the RAC map of the four audit companies, the states they will audit and the contact numbers for each company.
- Diversified Collection Services 866-201-0580
- CGI Technologies and Solutions 877-316-7222
- Connolly Consulting, Inc. 866-360-2507
- HealthDataInsights, Inc. 866-376-2319
Obama’s Unintended Consequences for Anesthesia
Michael Casey from the Associated Press Wire Service reported on an effort to preserve sea birds on Macquarie Island. All the cats on the island were removed or exterminated. Unfortunately, this led to an explosion in the rabbit population. The rabbits destroyed the vegetation that the birds required for cover. Ultimately, the move hurt the birds far more than the cats ever could have. This story provides an illustration of the law of unintended consequences. Manipulation of complex and sensitive systems carries with it both risks and benefits. Change in one area typically impacts others.
President Barack Obama has made health care reform a priority. In doing so the House has drafted a bill (e.g. HR3200), that in its present form will decimate the speciality of anesthesia, an unintended consequence. The president intends to insure affordable healthcare and improve access, but by doing so he will cause unintended consequences that will be counter to his objectives. By using the Medicare fee schedule as the basis for payment under the proposed “Public Option” health plan the government has signed the death warrant for the specialty of anesthesia .
Medicare payments for anesthesia services are calculated using a different method and a different “conversion factor” than that used for other medical specialties. While Medicare pays primary care and other physicians an average of 80% of private sector fees, according to the GAO, Medicare rates for anesthesia providers average only about 33% of what private insurers pay for our services, across the country. This unequal treatment is already driving many anesthesia providers to seek early retirement and it will ultimately limit patients’ access to anesthesia care as fewer anesthesia providers enter the specialty. Payment rates in any health plan, including a potential “Public Option”, must be fairly negotiated to encourage all providers to participate. Anesthesia providers need to educate House members on this unintended consequence so that it can be removed from the bill or the bill modified to correct the unintended consequence for anesthesia.
