Home Health & Hospice

It's Time to Meet the RACs

Homecare Insider, April 20, 2009

Last year, most homecare clinicians probably thought a RAC had to do with barbequed ribs.  That is changing.  The Recovery Audit Contractor (RAC) program has become permanent and will expand to homecare agencies sometime this year.  

Homecare veterans can’t help but think back to Operation Restore Trust (ORT), a nightmare for homecare providers in the mid-1990s.  As we learn more about the RACs, we don’t think this program will be as horrific as ORT.  There will be more structure, an advance notice of the issues, a limit on record review, a rebuttal and appeals process, and a validation study of the accuracy of RAC decisions.  However, there are still reasons to be very concerned.  The RACs can look at any claim at any time during the care delivery cycle.  And there will also be extrapolation, the extenuation of the denial rate to a larger population of claims.

A RAC can look at three years of claims, but only claims on or after October 1, 2007, are subject to review.  There is not much an agency can do about care that it has already provided, but there’s plenty that can be done about care provided from this moment forward.  An agency should take every possible step to ensure that care delivery complies with applicable regulations and criteria, and that the documentation is complete, correct, and comprehensive.  One strategy for success:  Start looking at every case within a few days of admission.  Beacon Health has seen too many times when care started off on the wrong foot and the agency never did recover.  During the review, verify that the patient qualifies for Medicare coverage.  Check that the plan of care builds a case for reasonable and necessary skilled services and includes appropriate and complete orders.  Confirm that staff are implementing the plan of care properly.  

If you need to know more about the RACs but time is tight, consider the audio recording, “Get Ready:  Here Come the RACs.”  — for information.