Revenue Cycle

Medical records compilation: Handle RAC documentation requests

Recovery Auditor Report, December 24, 2009

The medical record compilation process begins when the RAC makes a request, which must promptly reach the correct hospital department to ensure that there is sufficient time to compile and review the records before submission.
Some hospitals may elect to have the requests go to their medical records or health information management (HIM) department because the staff can quickly compile the records. However, hospitals with RAC coordinators should consider having RACs send the requests to the coordinator, who will watch for trends in requests and ensure that RACs do not exceed records request limits.
You may choose to have the HIM department compile records for submission or elect to have an outside release-of-information company compile the records. Some release-of-information vendors have systems for tracking the requests as well as other information, such as receipt of records, denial status, and appeals information. Although their primary purpose is to ensure that records are compiled and submitted in a timely manner, these additional software system features may be a good choice for some providers as a method for tracking the entire RAC process.
Regardless of whether an internal department or a vendor compiles the records, you should ensure that they submit all the records, including hard copy records, electronic records, financial records (e.g., ABNs or HINNs), and records maintained in the clinical department on their systems. Additionally, you may wish to make and retain an additional copy of the submitted records for the RAC coordinator to use in the event of a denial to determine whether to appeal.
You can submit hard copy of scanned records by mail, or, in some cases, via fax. If you scan copes to a CD or DVD, you should ensure that you are meeting all the RAC requirements regarding format of the files on the disc.
Once compiled, you may elect to have the RAC coordinator, an internal auditor, or a clinical department representative review it for completeness prior to submission. The designee should review the record as it has been compiled—not originals in the medical records systems—to ensure that he or she sees exactly what the RAC will look at upon its review. Reviewing the record before submission can help you avoid denials based on missing information. It is generally worth devoting staff time to this review, unless the provider is very short-staffed, because if you do receive a denial based on missing records, it will take substantial efforts to attempt to overturn the denial. The reviewer may also look for potential errors in an effort to anticipate denials by the RAC. If staffing and resources are short, however, direct your efforts toward ensuring that the record is complete prior to submission and is submitted in a timely manner, rather than looking for anticipated errors.
The provider has 45 days from the date of the request to submit records, with 10 additional days for mailing time. Mail records well in advance of the deadline to ensure that the RAC receives them. Use a shipper with a method to track and verify receipt and consider mailing the records by day 30–35 after the date of the request. This will guarantee that there is sufficient time for the RAC to receive the records and input them into the system for verification by day 45. The RAC coordinator should verify that the RAC received the records by checking the RAC Web site beginning around day 40. This will allow the coordinator time to track the records through the shipper and ensure that the RAC did indeed receive them or resend them by day 45 if there was a problem with the submission.
Editor’s note: This article is excerpted from the new HCPro book, “The RAC Survival Guide ,” by Kimberly Anderwood Hoy, JD, CPC, director of Medicare and compliance at HCPro. Visit HCMarketplace for more information.

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