The Recovery Audit Contractor (RAC) initiative is a Centers for
Medicare and Medicaid Services (CMS) initiative that began in
2005 as a demonstration project in three states including
California. A permanent RAC program is begins in mid 2008.
Under the RAC program, private companies are contracted to
retrospectively review Medicare claims for potential
over-payments or under- payments.
CHA asks hospital leaders to contact their congressional
representatives soon in support of the Medicare Audit Improvement
Act of 2013 (H.R. 1250). The California delegation has continued
to add co-sponsors to the legislation, but there is still time to
add more. Today, Gretchen Case, director of compliance at
Cedars-Sinai Medical Center, participated in a congressional
staff briefing in Washington, D.C., about the legislation.
Today’s briefing presents an opportunity for hospital leaders to
now follow up with congressional staff on this important topic.
For more information on the bill, see CHA’s March 21
Advocacy Alert at
www.calhospital.org/support-changes-rac-program. Current
California H.R. 1250 co-sponsors include Reps. Julia Brownley,
Jim Costa, Susan Davis, Sam Farr, Jared Huffman, Doug LaMalfa,
Barbara Lee, Zoe Lofgren, Alan Lowenthal, Buck McKeon, Devin
Nunes, Ed Royce, Raul Ruiz, Adam Schiff, Jackie Speier, Loretta
Sanchez and David Valadao.
In an effort to enhance advocacy efforts in the coming months,
CHA reminds members to complete the American Hospital
Association’s (AHA) RACTrac survey by the deadline of this
Friday, April 19. RACTrac data will be used to analyze the
impact of the Medicare Recovery Audit Contractor (RAC) program on
hospitals and will help guide CHA’s advocacy for congressional
action on legislation that, if enacted, would make important and
necessary changes in the RAC program. AHA membership is not a
requirement to participate in RACTrac; CHA encourages all
hospitals to participate regardless of AHA membership status. For
registration information, contact AHA’s RACTrac Support at (888)
722-8712 or ractracsupport@providercs.com.
The Centers for Medicare & Medicaid Services (CMS) yesterday
distributed the attached temporary instructions for providers to
use in billing Medicare Part B services following denial of an
inpatient admission. Last month CMS issued an administrative
ruling and a proposed rule addressing the issue of Part B billing
following the denial of a Part A inpatient hospital claim by a
Medicare review contractor on the basis that the inpatient
admission was determined not reasonable and necessary. The
administrative ruling, which became effective immediately, will
serve as CMS policy until the proposed rule is finalized. The
temporary instructions apply to both Part B types of bills —12x
and 13x — and include both electronic and paper submissions.
CHA’s summary of the proposed rule is available at
www.calhospital.org/sites/main/files/file-attachments/hpa_summary_of_cms_ruling_on_part_b_rebilling.pdf.
In a win for hospitals, the Centers for Medicare & Medicaid
Services (CMS) issued the attached administrative ruling and a
proposed rule updating the Part B inpatient rebilling policy. The
administrative ruling acknowledges a number of recent decisions
by the Medicare Appeals Council and administrative law judges and
states that, effective March 13, when a Part A claim for a
hospital inpatient admission is denied by a Medicare review
contractor because the inpatient admission was not reasonable and
necessary, the hospital may submit a Part B inpatient claim for
services. The ruling applies as long as the denial was made: (1)
while the ruling is in effect; (2) prior to March 13, and the
timeframe to file an appeal has not expired; or (3) prior to
March 13, and an appeal is pending. The ruling does not apply to
Part A hospital inpatient claim denials if the timeframe to
appeal expired prior to March 13, and it does not apply to
inpatient admissions deemed by the hospital to be “not reasonable
and necessary” (for example, through utilization review or other
self-audit). Additional details regarding the time period for
billing, scope of review, patient status and operational
considerations are discussed in the ruling. The ruling will
remain CMS policy until CMS has finalized its proposed rule, also
released yesterday.