4 Key Considerations for ASCs Facing Medicare RAC Audits
At the 20th Annual Ambulatory Surgery Centers Conference in Chicago on Oct. 25, Stephanie Ellis, RN, CPC, owner and president of Ellis Medical Consulting, pinpointed some ways for providers to deal with RAC audits.
1. Anticipate and prepare for audits.
Providers can prepare for RAC audits in various ways. First, they should have compliance plans that are up-to-date and deemed effective by the Medicare program, according to Ms. Ellis. They should also identify a staff member to deal with RAC issues "who is very detail-oriented and who will take care of these, not stick them in a drawer and not respond," she said.
Among other strategies, surgery centers can also ensure they keep up with Medicare coding rules and guidelines, keep track of denied claims and monitor RAC audit focus issues, which are published regularly by the contractors.
2. Don't be afraid to fight if you think the auditors are wrong.
If surgery centers don't agree with the RAC findings, Ms. Ellis advised them to aggressively appeal. Providers can send a discussion letter to the contractor and must file a formal appeal within 120 days of the date of the RAC demand letter.
"They count on you to be complacent and not fight them," she said. "If you fight them, you're likely to have success."
3. Accept the penalty if auditors correctly identify errors.
On the other hand, if a provider agrees with the RAC contractor that errors have been made, they should simply pay the owing amount and work on avoiding the issue in the future.
"Make plans to make sure you don't have the problem again," she said.
4. Avoid common documentation issues that affect billing and coding.
There are various documentation problems surgery centers should look out for to avoid billing issues, Ms. Ellis said. For instance, "canned" or "cloned" operative reports might not include all of the information needed for proper documentation of procedures, she said. It can become a compliance issue if reports aren't accurate, detailed and individualized.
"It's very important that the diagnosis for the patient and anatomical area is indicated, along with complications," she said.
More Articles on ASC Audits:
Prepping for Medicare Inspections: Tips From 3 ASC Administrators
9 Steps for ASCs to Achieve & Maintain HIPAA Compliance
RAC & CMS Audits: Top Documentation Issues for ASCs & How to Reduce Risk
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