Recent RAC Updates

Additional Documentation Limits for Medicare Providers

Effective August 22, 2011, the Recovery Audit Contractors are permitted to request up to 35 records every 45 days from health care providers whose previous record request limit was set at 34 additional documentation requests or less. The limit is based on claim volumes only, and the type of claims do not factor into the limit. The maximum number of record requests remains at 300 within 45 days.

http://www.aha.org/aha/content/2011/pdf/11racadrlimits.pdf

New Approved Issues

CGI Federal, RAC for Region B, added one new issue to its CMS-approved issues list.

• Multiple DME rentals billed per month. Medicare makes payments on a monthly basis for the rental of DMEPOS Fee Schedule items. The first claim’s billing date for the DMEPOS rental item is designated as the anniversary date. All subsequent billing must be dated monthly with the anniversary date. If a claim is submitted with a date that is earlier than the anniversary date and that DMEPOS item is not a replacement for a lost, stolen or irreparable damaged DMEPOS item, then the claim represents an overpayment

HealthDataInsights, RAC for Region D, added two new issues to its CMS-approved issues list.

• Facet joints denervation billed without guidance J1-by ASC. In accordance with LCD L28288, Facet Joint Denervation requires placement of a needle in the facet joint under fluoroscopic or CT guidance. This requirement is effective for dates of service on or after September 2, 2008 in California, Nevada and Hawaii.
• Age-appropriate code for end stage renal disease (ESRD) services. The beneficiary’s age at the end of the month is the age of the patient for determining the appropriate age based ESRD-related services code.

If you need assistance in preparing for, or defending against RAC audits, or implementing a compliance program geared toward identifying and correcting potential risk areas related to RAC audits, please contact a Wachler & Associates attorney at 248-544-0888.