2009-08-13

The Recovery Audit Contractors (RAC) Program continues to gear up with the Centers for Medicare & Medicaid Services (CMS) timeline showing that some states may have already begun automated reviews. ASH, along with several other medical societies, has expressed concerns to CMS about the RAC process.

CMS has responded to concerns by describing a number of steps that it believes will protect against overly aggressive reviews, including: creating a New Issue Review Board that must approve any issues a RAC intends to pursue, retaining a RAC Validation Contractor to review RAC findings, and requiring that RACS refund their fees if determinations are overturned. CMS also states that it does not intend to have the RACs begin reviewing the levels of an office visit and/or consultation service without advance notice to the American Medical Association and physician community, except in some circumstances, such as duplicate claims, unbundling, and correct choice of new or established patient codes. Finally, the RAC may only request records and conduct review on 10 pilot cases before requesting further approval through the CMS New Issue Review process. ASH will continue to monitor the development of the RAC program and keep members apprised as this program becomes more widely implemented.

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