RACs – Alive and Well, Waking UP
by Leslie Johnson, CPC
CMS’s Recovery Audit Contractors (RACs) are alive and well and are gearing up for work as they wake from their long sleep. On Nov 13, 2017, proposals have been submitted for approval to begin audit recovery in the following areas, affecting all states, all MACs.
It’s not enough that you do periodic internal audits to make sure your coders’ accuracy rate are high. Periodic audits focused on areas of vulnerability, such as the overuse of modifiers 25, 57 and 59, can help you before your company is targeted for recovery.
The following are the coding areas that the proposals seek to audit. Direct link follows.
- Inpatient Rehabilitation Facility (IRF) Stays: Meeting Requirements to be considered Reasonable and Necessary
Affected codes: Not code specific
- Respiratory Assistive Devices: Meeting Requirements to be considered Reasonable and Necessary
Affected codes:
- E0470 – Respiratory Assist Device, bi-level pressure capability, without backup rate feature, used with noninvasive interface, e.g., nasal or facial mask (intermittent assist device with continuous positive airway pressure device)
- E0471 – Respiratory Assist Device, bi-level pressure capability, with back-up rate feature, used with noninvasive interface, e.g., nasal or facial mask (intermittent assist device with continuous positive airway pressure device)
- Excessive or Insufficient Drugs and Biologicals Units Billed
Affected code(s):
- C9025, C9295, J0129, J0178, J0256, J0583, J0585, J0894, J0897, J1300, J1459, J1561, J1566, J1569, J1572, J1745, J2323, J2353, J2357, J2505, J2778, J2796, J2997, J3101, J3262, J3487, J7325, J9033, J9035, J9041, J9043, J9055, J9171, J9228, J9263, J9264, J9299, J9303, J9305, J9306, J9310, J9351, J9355, Q2050, J9034, J9310
- E&M Codes billed within a Procedure Code with a “0” (Endoscopies or some minor surgical procedures), “10” and “90” Day Global Period[1]
Affected code(s):
- 92012, 92014, 99211, 99212, 99213, 99214, 99215, 99217, 99218, 99219, 99220, 99221, 99222, 99223, 99231, 99232, 99233, 99234, 99235, 99236, 99238, 99239, 99241, 99242, 99243, 99244, 99245, 99251, 99252, 99253, 99254, 99255, 99291, 99292, 99315, 99316, 99347, 99348, 99349, 99350, 99374, 99375, 99378; and All CPT and HCPCS codes with MPFSDB Global Days values of 000, 010 and 090
[1] CMS https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Recovery-Audit-Program/Provider-Resources.html
