RAC Audit Phase-in Strategy: Complex reviews to arrive as soon as August

July 2009

CMS released further information June 24 on its RAC Web site letting healthcare providers know when they can expect RACs to begin auditing. The new “CMS RAC Review Phase-in Strategy,” details different types of reviews and dates CMS anticipates the reviews will begin in various areas of the country.

The new information is consistent with CMS’ previous indications that some providers may begin to undergo automated review this month.

According to the CMS, the earliest possible dates for RAC reviews in yellow and green states are:

    June 2009—Automated reviews of black and white issues
    August or September 2009—Complex reviews for DRG validation
    August or September 2009—Complex review for coding errors
    Fiscal year 2010, which begins October 1, 2009—Complex reviews for durable
      medical equipment (DME) medical necessity
    Calendar year 2010—Complex reviews for medical necessity

The earliest possible dates for reviews in blue states generally fall a bit later:

    August 2009—Automated reviews of black and white issues
    October or November 2009—Complex reviews for DRG validation
    October or November 2009—Complex review for coding errors
    Fiscal year 2010—Complex reviews for DME medical necessity
    Calendar year 2010—Complex reviews for medical necessity

MAP:  http://www.cms.hhs.gov/RAC/Downloads/RAC%20Expansion%20Schedule%20Web.pdf

CMS also reaffirmed that before RACs actively begin auditing in a particular state, outreach educational sessions must occur in that area.

Although the schedule calls for automated reviews as early as this month, any issue a RAC reviews must be vetted through the CMS’ “Issue Review Board.” In addition, RACs must post the approved issues to their Web sites before the reviews can begin.