Get your RAC teams ready now, because the medical record requests alone can bury you.
That's the message I took from the Healthcare Financial Management Association's ANI conference in Seattle.
The Tenet Experience
The session presented by Tenet Healthcare included a brief overview of the RAC program. Following that was an outline of Tenet's response to RAC requests and audits. Tenet chose to have patient financial services be the division responsible for responding to the RACs, including coordination with clinical and non-clinical staff.
Fortunately for Tenet, all of its facilities have an installed EMR. Issues did arise from some requested records that predated the EMR system, but the local HIM departments seemed capable of handling them manually. PFS also was responsible for involving CM/UR with issues involving incomplete records or record reviews, for determining any rebilling possible and for coordinating efforts to make reports available throughout the system.
Each hospital was tasked with supplying complete support for its PFS department, including the services of a hospital-based RAC task force made up of representatives of HIM, coding, DPS, HCO, finance, CMO, CM/UR and of course PFS. The hospitals also were responsible for providing education for physicians and their practices.
Tenet used several multi-disciplinary teams at each site to support all this activity. Their titles are fairly self-explanatory, and included the following:
- Corporate RAC Steering Committee
- Hospital-based RAC Task Force
- Medical Record Provision Workgroup
- PFS Workflow Team
- PFS Medicare RAC Tracking & Reporting Team
RAC Tracking
Perhaps the most useful details in the presentation concerned the data the company tracked during the RAC process.
Demographics Tracked:
- Facility
- RAC audit letter ID#
- Account No.
- Patient name
- Medical record No.
- HIC No.
- Admit & discharge dates
- Total charges
- DRG assigned
- PxDx (frankly, we also would suggest all secondary Dx & ICD codes be tracked)
- Admit/attending physician
- LOS
RAC Request Data Tracked:
- RAC firm name
- Date of RAC record request letter
- Date requested records due to RAC
- Date records sent to RAC
- Date records received by RAC
- Method of record delivery (with tracking number & status)
- Type & page/file count of records sent to RAC
- Copy/duplication cost of records sent
- Delivery cost of records sent
- Hospital invoice
- Date of RAC review result letters
- Date of RAC demand letters
- Date RAC demand letters received
Dynamic RAC Data Tracked: (Audit Category)
- Request for records
- Payment correct (result of review was negative for errors)
- Underpayments (just a number count with a running total in dollars)
- Overpayments by type
- Not medically necessary, service (service deemed not necessary)
- Not medically necessary, setting (setting: OP billed as IP)
- Discharge status conflict
- Accounts not combined
- Incorrect units charged
We would advise perhaps adding more types of overpayments, such as those rendered due to various types of coding errors, and in particular those cited as being "not medically necessary due to lack of documentation."
If all that data and the need to track it accurately don't make you dizzy, then I don't know what will (perhaps you should be writing articles about RAC tracking?)
This blog originally appeared at RACMonitor.com.
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