New data seems to show the Recovery Audit Contractor program is increasing its denial of claims by providers. Physical therapist managers who bill the Medicare program are paying close attention to RACs even though small practice physical therapists' clinics have not been typically targeted by RACs.
Most of the RAC activity is targeted at the largest cost centers - that is, the hospital.
Beginning April 1st, however, small practice physical therapists that fall under the Medicare Part B $3,700 cap on physical and speech therapy will face RAC audits. The RACs will be performing both pre- and post-payment audits for the manual medical review (MMR) process.
RACs typically cite medical necessity as their number one reason for denial of claims. Altogether, the program corrected $5 billion in faulty Medicare payments since it began in October 2009, according to CMS.
Click through this image below for the April 2013 RAC results to date:
|RAC result to date from the inception of the program in 2009|
The American Physical Therapy Association (APTA) has a page of resources for physical therapists who want to comply with RAC requirements (membership required). Check out this story at FierceHealthCare.com with additional links.
Tips to protect yourself from a RAC audit:
Educate yourself - the Florida Physical Therapists in Private Practice (FLPTPP.com) has a full day of educational programming May 18th, 2013 in Orlando, Florida geared towards recognition of risk and compliance with RAC audits, G-codes and the Manual Medical Review process.
Establish a compliance plan and conduct self-audits - hundreds of physical therapists have used this e-mail version of the Office of the Inspector General (OIG) Small Practice Compliance Plan to learn the steps - one of which is self audits:
Ensure follow-up - if you do get a RAC demand letter appoint one person in your office to immediately follow-up. You usually have a deadline, such as 30 days, to respond.