RAC audits keep provider awake


Provider Gary Rench owns a small DME company, Sandcreek Medical in Sandpoint, Idaho. In a letter to HME News, he says he's just a normal guy trying to play by the rules and make a living.

This morning I awoke at about 4 a.m. dreaming of the RAC audit I have to address. Since I cannot sleep I may as well go to the office.

There, in my e-mail (from AAHomecare): "RACs Erred with CPAP Policy; Refunds Possible."

I do not know who the RACs are; I do not know who works at HDI.

I am always looking at the LCD to see if we are within the rules. Sometimes it is very complicated and I cannot walk up to a desk or phone a person at Medicare that will really answer a question.

It is 6:00 in the morning and I just finished my letter on my RAC audit. All week I have tried to get the letter written but I have been busy running a business. I am also on a tight schedule, because one of the rebuttal time frames is 15 days from the date of the letter. The letter was dated the 17th, it was postmarked the 22nd and I happened to pick the mail up on the 26th.

Anyway, as I was sitting here by myself, I started thinking. Had the doctor not noted in his chart that this patient was using CPAP, I would have lost $824.78. I do not have a lot of control over what the doctor notes, but (luckily) the note was there. One missed note and I would have had to repay the whole claim.

The RAC has pulled three of my CPAP patients to audit. On one of the audits, I received a duplicate audit letter. It was noted by Peggy Walker (billing and reimbursement adviser for the VGM Group's U.S Rehab) that there are duplicate audit letters going out and you should address both of them.

Now we read that the RAC has misinterpreted the policy. Will they be paid for their work? Will they have to pay back the payment they received because they misinterpreted the policy?

That's what happens when I misinterpret the policy.

I am going home to shower now, and take my kid to school. Then I will come back to work and start the faxing process to the RAC.

Theresa Flaherty



Thank you for posting this letter.  It is nice to know we are not the only ones.  This gentlemen describes our feelings, fears, and experiences perfectly, and we do diabetic supplies, not CPAP.  

It just simply feels like unfair, unconstitutional persecution.  We feel absolutely helpless.  We lay awake wondering whether - if we get too many doctors who don't document per CMS/RAC's/ZPIC's unwritten rules - we will get put on pre-pay audit status (who knows what the criteria are for that, if any - and have to lose our business.   It's a very scary, uncertain environment and feels like they are only punishing those who are trying to live within the (conflicting) rules.

I guess misery loves company, but thank you.

Sincerely, Mike Walsh
Western Diabetic Supplies