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Essential questions every HIM director should ask about RAC record requests

Recovery Auditor Report, June 25, 2009

• What is our volume of claims that fall under each RAC-identified issue? Once RACs begin posting the issues they intend to audit on their Web sites, determine whether your hospital’s volume in these areas (e.g., one-day stays) is high, says Camille Cohen, MBA, MSW, CHC, compliance solutions manager at 3M Health Information Systems in Salt Lake City. Your claims might be compliant, but a RAC could still request a large number of records because of your high volume. Responding to the requests could have considerable operational ramifications, including having to track and respond to those requests, she says.
• Do we need to hire additional staff members? This is a difficult question to answer for HIM directors, primarily because record requests could arrive arbitrarily or separately throughout a 45-day period. Because of the inconsistency, assessing whether an additional staff member is needed may be difficult, says Cohen. However, directors can and should begin to track the timing of requests upon receipt. “Initially, you may see more sporadic requests because the RACs are gearing up. After that, there may be more of a pattern to it,” she says. And don’t be afraid to seek help outside the HIM department. “There may be some function that you can off-load during a high peak time,” she says. Consulting firms you have worked with in the past may be another option.
• Will we require staff members to review records before we send them to the RAC? Reviewing records before staff members send them to the RAC adds processing time, but is wise because it helps ensure that the response is complete and no documentation is missing, says Cohen. This extra step also helps identify potential inaccuracies before the RAC does.
• Who will we assign to process record requests? Identifying the individual who will receive record requests is important to ensure compliance with the 45-day response time, says Cohen. Directors should pay close attention to the initial letter because RACs will use it to communicate the specific request limit for each organization. Hospitals may identify the designated contact person by registering this information on their RAC’s Web site. Create a process and assign a backup contact person for days when the designated individual is out of the office, says Cohen. In addition, some hospitals may decide to use a post office box for all RAC-related communications. Currently, RACs will communicate with hospitals via the U.S. Postal Service only. Using a post office box can help prevent lost and misplaced letters in a busy mailroom.
• Will we monitor the total number of requests we receive every 45 days? RACs may request a maximum of 200 records every 45 days, so ensure that they don’t exceed this limit is important. “In the demonstration program, some of the RACs made mistakes,” Cohen says.
• Which format should we use when responding to record requests? CMS requires that RACs have the ability to accept paper records and scanned images on a CD or DVD. Beginning in 2010, RACs must also accept imaged records electronically, according to the advisory. Hospitals must decide which (e.g., paper, DVD, or CD) is most feasible. This decision is particularly important for hospitals with a hybrid paper and electronic record, says Cohen. Sending your record in more than one format is inadvisable because it requires that someone outside your hospital is responsible for combining information. “Either print your electronic or scanned record or scan your print copy so you can ensure everything is together before sending it to the RACs,” Cohen says.
• Will we retain a copy of records we send to the RACs? Retaining a copy of records you’ve sent to your RAC can be helpful in case the RAC doesn’t receive them and when appealing denials, says Cohen. Hospitals should ensure that they store copied information securely, regardless of whether it is a paper duplicate or a scanned image, she says.

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