The best defense for healthcare organizations against the RAC audits is a good offense, says a 20-year veteran of the healthcare industry and expert in organization performance improvement.
In a Wednesday session of the Healthcare Finance News Virtual Conference, Stephen Forney, vice president of margin development at Ardent Health Services, a Nashville, Tenn.-based operator of eight hospitals in two states, listed the steps that a healthcare provider should take to prepare for a RAC audit, including developing internal polices and learning about the appeals process.
According to Forney, providers preparing for a RAC audit should:
- Assess exposure and determine exposed business units, making sure to include representative of all business units in process and education initiatives. Don’t ignore units due to low volume/low dollars.
- Develop an internal audit program to determine current exposure and create processes to correct. Use the RAC demonstration project, conducted between 2005 and 2008, as a model.
- Educate employees/stakeholders to minimize future exposure.
- Establish organizational roles for RAC responses, including a chief RAC officer and a steering committee.
- Develop a RAC communications repository as a tracking tool for all communications. It’s necessary to track timelines and trends.
- Develop communication polices, as it's important for all employees to know their role when dealing with RAC issues. And make sure to est the workflow.
Forney said the appeals process can be lengthy and complex, and he advised those choosing to appeal to be "very aggressive."
"If there’s any reason for appeal, do it," he said. "You don’t want a low-dollar claim to become repeated evidence of fraudulent activity in the future."
To cover expenses created by an audit, Forney said organizations should look at DRGs and online payments to increase collections.
“We don’t know what we don’t know yet,” he said. “We should be wise about this and perceive things that are about to happen.”
He also encourages organizations to communicate with their RAC regional contractor before they come to town and keep the lines of communication open.
The four RAC auditors assigned by CMS are:
- Diversified Collection Services, Inc., of Livermore, Calif., in Region A (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, New York, Connecticut, Pennsylvania, New Jersey, Delaware, Maryland and Washington D.C.);
- CGI Technologies and Solutions, Inc., of Fairfax, Va., in Region B (Michigan, Indiana, Minnesota, Wisconsin, Illinois, Ohio and Kentucky);
- Connolly Consulting Associates, Inc., of Wilton, Conn., in Region C (South Carolina, Florida, Colorado, New Mexico, West Virginia, Virginia, North Carolina, Tennessee, Arkansas, Oklahoma, Texas, Louisiana, Mississippi, Alabama and Georgia); and
- HealthDataInsights, Inc., of Las Vegas, Nev., in Region D (Montana, Wyoming, North Dakota, South Dakota, Utah, Arizona, California, Nevada, Washington, Oregon, Idaho, Alaska, Hawaii, Nebraska, Iowa, Kansas and Missouri).