You can look forward to overpayment demand letters -- based on audits by your recovery audit contractor (RAC) -- coming from your Medicare Administrative Contractor (MAC) or carrier, starting Jan. 1, 2012. Your MAC or carrier will now issue the demand letters, but everything else about the recoupment process will stay the same, including the 40-day discussion period and the appeals process.
In 2012, RACs themselves will continue to be the entity you contact for "audit-specific communications," such as exchanges during the discussion period and questions about the details of audit findings. MACs will handle "administrative concerns," which include the appeals process and the actual offsetting of your alleged owed amount against incoming Medicare payments.
None of the timeframes associated with RAC overpayments, such as the 120-day timeframe for beginning appeals via redetermination request, will be changing. RACs have increasingly begun targeting physician practices, particularly based on post-payment, "complex" reviews of National Correct Coding Initiative (CCI) edits. I'll be posting more on that later.