Audit / CMS / Oig / RAC / Toolkit

Recovery Audit Contractors: Know These RAC Fast Facts

RACs are just another tool in the government’s arsenal to collect improper payments.

You’ve got so many compliance acronyms flying at you every day that you may not be able to differentiate your RAC from the OIG. Know these quick facts about RACs to stay better informed.

  • Recovery audit contractors (RACs) detect and correct past improper payments so CMS and the MACs can prevent such problems in the future
  • RACs are hired as contractors by the government, and they can can collect “contingency fees,” which means that they get a percentage of the amount that they recover from providers who were paid inappropriately The maximum RAC lookback period is three years, and they cannot review claims paid prior to Oct. 1, 2007
  • Between 2005 and 2008, RACs involved in the original demonstration project recovered over $1.03 billion in Medicare improper payments, but referred only two cases of potential fraud to CMS, according to a February OIG report on the topic, which noted that “because RACs do not receive their contingency fees for cases they refer that are determined to be fraud, there may be a disincentive for RACs to refer potential cases of fraud.”
  • Unlike RACs, the OIG is a government entity. Although the OIG also performs reviews and audits and seeks improper payments, the OIG does not collect contingency fees.

For more on the RAC program, visit www.cms.gov/rac.

@ Part B Insider. Editor: Torrey Kim, CPC

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May 24, 2010
Medicare / Oig / Provider News

Cost of Freezing Conversion Factor is Over $6 Billion — Just for 2010

Plus: The OIG recovered over $1.5 billion in fiscal year 2009, and is on the lookout to collect more.

With less than two weeks to go before Medicare payments once again threaten to decrease by 21 percent, a new report sheds light on the financial outcome of Congressional actions.

Although the 2010 Physician Fee Schedule originally included a conversion factor that would have been 21 percent lower than the 2009 level, practices haven’t felt that cut yet this year,because legislators have voted several times to freeze payments, which now use the conversion factor of $36.0791. That freeze will expire on May 31, after which your Medicare payments will drop considerably unless Congress steps in once more.

However, one government entity’s calculations show that the freeze is costly. According to a May 7 Congressional Budget Office report, freezing payments at the current levels for the rest of 2010 would cost the government… … $6.5 billion. The AMA has turned up the heat on Congress to replace the current payment method, releasing a print ad aimed at Congress to demonstrate that “more delays of permanent reform now increase the cost for taxpayers,” and that the association “calls on Congress to fix the flawed Medicare physician payment formula now.”

Congress has not yet introduced a bill to extend the payment freeze past May 31. Keep an eye on the Insider for more information as this story develops.

To read the Congressional Budget Office’s calculation sheet,visit www.cbo.gov/budget/factsheets/2010b/SGR-menu.pdf.

@ Part B Insider. Editor: Torrey Kim, CPC

Sign up for the upcoming on-demand Webinar, 5 Steps to Optimize Your Office’s Coding & Billing Practices, or order the CD/transcripts.

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May 24, 2010
Hot Coding Topics / Medicare / Oig / RAC

Gastro Coders: Be Aware of Medicare Screening Reqs Or Risk Payment Denial

Following 10-year-rule eliminates G0121 rejection.

If you slip up on screening colonoscopy claims’ frequency guidelines and eligibility requirements, Medicare will pay you zilch.

Use this guidance to capture every screening dollar your gastroenterologist deserves.

Home in on Eligibility Requirements for...

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April 12, 2010
CMS / E/M / Medicare / modifier 25 / Oig / Toolkit

Use This Sample Appeal Letter As Ammo in Your Fight Against Modifier 25 Denials

Attach your procedure notes and the OIG’s report to pack extra punch.

Even if you follow all of CMS’s rules in reporting modifier 25 (Significant, separately identifiable evaluation and management service by the same physician on the same day of the…

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March 12, 2010
CCI / HCPCS / Hot Coding Topics / Medicare / modifier 59 / NCCI / Oig / Oncology

OIG Hit List: Perfect Your 38220, 38221, and G0364 Usage

Don’t sweat reporting 38220-59 if you meet these Medicare-approved conditions. If your oncologist takes both a bone marrow biopsy and a bone marrow aspiration, whether you’ll see Medicare reimbursement depends on the two guidelines below. But watch out: With OIG scrutiny and a HCPCS twist, these guidelines will put your coding savvy to the test. Append 59 [...] Related articles:

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February 21, 2010
Hot Coding Topics / modifier LT / modifier RT / Oig

Coding Compliance: OIG Targets Transforaminal Epidural Injections

Verify that you’re counting injections and levels correctly to keep claims clean. The Office of Inspector General (OIG) Work Plan for 2010 includes a closer look at Medicare payments for transforaminal epidural injections. The Work Plan specifically states, “We will review Medicare claims to determine the appropriateness of Medicare Part B payments for transforaminal epidural injections.” Stay [...] Related articles:

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February 17, 2010
Coder's Cranium / Medicare / Oig

Nonphysician Providers and Incident-To: Your Coding Questions Answered

Here’s why you should keep your physicians’ work schedules on file. Correctly billing your nonphysician practitioners (NPPs) incident-to services means the difference between 85 and 100 percent reimbursement. But if you bill incident-to haphazardly, you’re just waving a red flag at auditors. And those auditors are jonesin’ to find incident to billing problems. Just check out this [...] Related articles:

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October 25, 2009
Audit / Hot Coding Topics / Oig / RAC / radiology

Double Ultrasound Codes Spell Double Trouble With Auditors

Authorities scrutinize medical necessity for 76830 & 76856. The OIG is watching your ultrasound orders and code combinations — and it doesn’t like what it sees. Take note of these problem spots to keep your claims in the clear. An OIG audit of ultrasound services billed in 2007 found that nearly one in five ultrasound claims “had characteristics that raise [...] Related articles:

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October 24, 2009
Audit / Cardiology / Oig / Provider News

OIG Auditors to Cardiologist: You’re Billing Medicare Properly

Report reveals what he and his billing staff did right. Does your practice have the right stuff? Turns out the old saying is true: If you haven’t done anything wrong, an OIG audit is nothing to worry about. A New York cardiologist who collected over $1.3 million over a three-year period for 5,061 claims caught the OIG’s [...] Related articles:

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October 20, 2009
Audit / Hot Coding Topics / Oig

Service Doesn’t Meet Incident-To Rules? Report Under NPP’s NPI

Heads up: These vaccine admin codes are excluded from incident-to requirements. Incident-to rules don’t always apply to diagnostic services, but many medical practices aren’t aware of that. And based on a new wave of scrutiny directed toward incident-to claims, you should know physician supervision rules inside and out. A recent audit from the HHS Office of the Inspector [...] Related articles:

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October 20, 2009