TMA is receiving more and more calls from physician offices that have received a records request or repayment letter from Connolly, Inc., the Medicare Recovery Audit Contractor (RAC) for Texas.
RAC audits nationwide have ramped up [PDF]; since the program became permanent and went nationwide October 2009, Medicare has recouped $575.2 million in overpayments it made to physician practices, and disbursed $109.6 million to practices to rectify underpayments.
In Region C, which includes Texas, Connolly’s top recovery issue has involved payment for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) provided during an inpatient stay. (Medicare does not make separate payment for DMEPOS when a beneficiary is in a covered inpatient stay.) However, the list of issues for which Medicare has authorized Connolly to audit physicians and providers is extensive.
Received a Records Request or Repayment Letter?
If you receive a records request, make sure the services in question are within the period subject to RAC review. RACs may go back only three years and cannot review claims from prior to Oct. 1, 2007. Respond to valid records requests promptly.
If you receive a repayment request, you have three options for disputing it, if warranted. Be sure to pay attention to the deadlines for each.
- You can open an informal discussion with Connolly to provide additional information or explain your rationale for the disputed charges. Connolly may reconsider its payment request.
- If the repayment will cause a financial hardship for your practice, you can use the rebuttal process to provide a statement and evidence of hardship.
- You may request a redetermination, which is the first stage of appeal of an overpayment decision. Medicare offers five levels of appeals, which you should seriously consider pursuing if appropriate. Physicians have prevailed in about one-third of the cases they’ve appealed nationwide.
If you have questions, call the TMA coding and billing hotline at (800) 880-1300, ext. 1414.
Remember, one of a practice’s best lines of defense for avoiding a RAC audit in the first place is a policy of regular coding and documentation audits, whether performed internally or by an outside consultant such as TMA Practice Consulting. Also, TMA’s recorded one-hour webinar Avoiding RAC Audits discusses self-audits, what to do with your findings, and how to get buy-in for corrective actions.
Published Aug. 26, 2011
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