Recovery Audit Contractors (RACs) say they're laying all their cards on the table -- via provider outreach and RAC websites -- showing you how they'll go about recouping improper payments from your practice. However, they still have a few cards up their auditor sleeves.
The RAC process is agreeably more transparent than the RAC demo a few years ago, but the process is still quite opaque.
Here's my gripe: We know RACs have dozens of issues -- more commonly referred to as "targets" -- they're planning to use to collect billions of dollars. But for unknown reasons these proposed targets won't be disclosed until they're approved and posted on a RAC website.
CMS obviously knows the proposed issues, too. An agency committee reviews each issue and approves them, but they don't show you what they're reviewing. You only discover what they've reviewed when the RAC publishes the issue online.
CMS would post all proposed issues on an agency website if the process was truly transparent and open. We'd also find out which issues failed to gain CMS approval.
Regardless, Medicare providers would be better served knowing future RAC targets.
Practices could then self-audit claims, and adjust their billing if mistakes are found. You and your peers could ensure they bill for and receive proper future payments sooner rather than later.
After hearing about the transparency efforts during a recent outreach session, I asked a DCS official what are some of the proposed issues they've sent CMS. The RAC won't have complex issues until they've been posted online, the official said while not answering the question asked.
She referred me and other providers to previous Comprehensive Error Rate Test (CERT) and RAC demo reports. "That's where we'll get some of the ideas," she said.
I didn't have a chance to ask a follow-up, but if the ideas for the targets are already out there why not acknowledge the ones you've sent to CMS? Why not tell providers which issues their RAC will go after from the start?
Only then would we see true transparency.