Revenue Cycle

Let's discuss the RAC discussion period

Recovery Auditor Report, July 23, 2009

It seems that many providers still struggle to understand the RAC discussion period that CMS has helpfully given them—much less take advantage of it when the permanent program rolls out in their area.

The discussion period is new to the permanent program, though it is somewhat akin to the rebuttal period, which was part of the demonstration program. “The rebuttal period was used in the demonstration because it is part of the Medicare appeals process,” says Camille Cohen, MSW, MBA, CHC, compliance manager at 3M Health Information Systems in Salt Lake City.

But CMS found providers had a slightly different need from the rebuttal process during the demonstration project, she says. Originally designed to discuss mathematical errors, providers instead used the rebuttal period for all kinds of discussions. Hence, CMS decided to initiate the discussion period specifically for RACs.

“The RACs and CMS are trying to work with providers, and the discussion period is a huge open door for providers to have a dialogue with their RAC,” Cohen says.

Providers can use this chance to communicate with their RACs to discuss much more than math. Not only can they use it to try to change the RAC’s mind on a denial, but they can use it as a learning opportunity. A RAC may discuss how it came up with the determination. Providers should seek out that information so they don’t keep making the same mistakes, says Cohen.

Visit the Revenue Cycle Institute blog to read the rest of the article.

Editor’s note: We would like to take a moment to welcome Camille Cohen, MSW, MBA, CHC, compliance manager at 3M Health Information Systems in Salt Lake City, to the RAC Report Advisory Board.

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