New RAC starts ‘slow and steady’

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Friday, March 24, 2017

LIVERMORE, Calif. – Performant Recovery was officially up and running as of March 8, but the new national RAC for HME is taking its time ramping up its activities.

Peformant posted seven new reviews for everything from chest wall oscillation devices to complex Group 2 support surfaces in February. But it had not posted any additional reviews as of late March.

“I would expect that they would add one or two edits every seven days to staff up to where they were at previously with known issues,” said Andrea Stark, a reimbursement consultant with MiraVista. “They may be taking a slow and steadier approach.”

There are others signs that the RAC process under Performant will be a smoother and more manageable one for HME providers.

Right out of the gate, Performant opened a line of communication with providers by hosting two webinars in conjunction with the two DME MACs, Noridian and CGS.

“That’s the first time we’ve seen a RAC do any kind of outreach,” Stark said. “That kind of early communication can’t be undervalued.”

Also, while providers have worried about whether or not Performant will apply the correct coverage policies—their reviews will span three years—that may not be an issue under the new RAC, stakeholders say.

“Initial discussions with the RAC do not indicate that this will be a concern,” said Wayne van Halem, president of The van Halem Group, a division of The VGM Group. “They’re aware of the fact that they must apply the rules in place on the date of service in question.”

Finally, providers have a more meaningful discussion period under Performant that will work in their favor. There’s always been a discussion period, but because previous RACs immediately signaled the MAC to start the overpayment process, the only way providers could hold onto their money was to file appeals. Now they have 30 days to work the process until anything is forwarded to the MAC.

“Oh yeah,” said Kim Brummett, vice president of regulatory affairs at AAHomecare, when asked whether or not she thinks providers will take advantage of the discussion period. “They should.”

Are you RAC ready?

Since it’s been so long since providers have had to grapple with a RAC, stakeholders offered these pieces of advice:

Be proactive.“Suppliers must have an internal quality assurance and compliance program that regularly monitors the claims that are being submitted,” van Halem said. “They should review the RAC website regularly to perform a risk assessment on their proactive audits. Suppliers can minimize the impact of these audits for themselves.”

Read carefully.“Some are medical necessity reviews and some are documentation reviews,” Brummett said. “Pay attention to your audit request letters and know which you are dealing with.”

Keep organized.“Use separator sheets to tell the auditors, this is where the face-to-face evaluation is, this is where the proof of delivery is,” Stark said. “They’re going to itemize the things they want you to send back to them, so make it as easy as possible on them. It predisposes you to a favorable opinion.”