An astute reader wrote me this morning noting Recovery Audit Contractors (RACs) will reimburse some providers for copying medical records, which would contradict a statement in my recent story on copy costs. She writes:
According to CMS: RACs are required to reimburse PPS providers and Long Term Care providers. The reimbursement rate is 12 cents per page for reproduction of medical records. Facilities are not required to submit vouchers to the RAC requesting payment. Rather, the RACs will automatically issue payments to the hospitals for photocopying charges. RACs are required to pay for copying on a monthly basis. All checks should be issued within 45 days of receiving the medical record.
And, she's correct.
However, I've been told by CMS officials that physicians will not be reimbursed. This issue has come up at almost every Practicing Physicians Advisory Council (PPAC) meeting I've attended. Here's a discussion on this issue during PPAC's June meeting:
[PPAC member] Dr. Arthur Snow: Okay. Secondly, I understand hospitals can charge and be paid for providing medical records for RAC audits. Is that correct?
Commander Marie Casey RN, CMS's deputy director of recovery audit operations: That's correct.
Dr. Snow: Physicians cannot?
Cmdr. Casey: That's correct.
Dr. Snow: There seems to be a slight difference there. What's the rationale for that?
Cmdr. Casey: I had to answer this question to a group of physicians actually in Oklahoma and they didn't really care for my response. But my understanding is that the agency has taken that policy because they believe that the cost associated with photocopying medical records are included in the Physician Fee Schedule, and similar to the other types of contractors that we do have, that happen to be medical review, they also do not pay for medical records from physicians. However, the QIOs for year have paid for medical records, because that was supposedly not included in the payment amounts that the hospitals received. So that's currently the position the agency's taking on whether to pay or not to pay.
Dr. Snow: So hospitals' costs are not included in their DRG payment, somehow.
Cmdr. Casey: Supposedly, the costs of the photocopying and submitting those medical records is not supposed to be one of the things that slipped out and added into the payment that they receive.
Dr. Snow: So, but it's an agency decision, then is what you're saying. It's not statutory.
All that said, I'll be writing a clarification on this point in the next newsletter issue.