Home Health & Hospice

Homecare Aptitude Test: RACs

Homecare Insider, June 29, 2009

Determine whether the following statements about the Recovery Audit Contractor (RAC) program are true or false.

a. RACs have been reviewing homecare claims since March 2009.
b. An agency may receive a request for records from a RAC before an intermediary’s additional development request (ADR).
c. A RAC can review up to 10 percent of a homecare agency’s claims within a 45-day period.
d. An agency can request to see the credentials of the RAC reviewers.
e. Upon receiving a demand letter to repay Medicare funds, an agency can rebut the findings directly with the RAC.

Scroll down for the answers.

Answers to the Homecare Aptitude Test  

Here are the answers to the questions about the RAC program.
a. False.  Some RAC programs were up and running as of March 1, 2009; the remaining will be operational after August 1.  The Centers for Medicare and Medicaid Services (CMS) said in a recent open door forum that it will begin providing information about homecare agencies to RACs in August.   
b. True.  A RAC can review a record at any time “from day one,” as CMS says.  That’s because CMS does not believe reviewers such as the Medicare Administrative Contractors (MAC) have the resources to handle as much timely review as may be necessary to control inappropriate payment.  
c. False.  CMS has established a structure for claims review.  The RACs are limited to a three-year look back period.  Only claims on or after October 1, 2007, are subject to review.  The limit for homecare providers is 1 percent of Medicare services during 45-day period with a maximum of 200.
d. True.  A RAC must employ certified coders and at least one medical director.  It must utilize nurses, therapists, certified coders, and a medical director in the review of claims.  The credentials of the reviewers will be available upon request.
e. True.  An agency can appeal the findings using the current Medicare appeals process.  There are five steps but only the first three—redetermination by the MAC, reconsideration by the Qualified Independent Contractor, and Administrative Law Judge hearing—are truly viable for a homecare agency.  There is one additional step when dealing with RACs; that being rebuttal of the findings to the RAC within 15 days of receipt of the decision.  Note this does not delay the 120-day clock for submitting a redetermination so an agency may want to request a redetermination at the same time it does a rebuttal.

Before we know it, the RACs will be reviewing homecare records.  It’s time to get up to speed about the program—the objectives, the operation, the risks, and more.  The audio recording, “RACs and Threats to Your Agency,” is a good way to start.  For more information, click here.