There’s no longer any way around it; I need a vacation.
According to the calendar, we now have 301 days left until the theorized Mayan Apocalypse. In the last week, the news cycle in the real, personal and professional worlds that surround me have taken a marked turn for the weird. It’s time to get out of here and explore such things as music, grilled meats and beverages unfit for your children.
Before I lock the doors of my car to prevent further interruption, I have a few updates involving government audits and (since I’m here and I have the floor) a timely news update about the “Doc Fix”.
First, CMS released the RAC results from the first quarter of Fiscal Year 2012. For the last month of 2011, $422.7 million in corrections were identified. Of the four regional contractors, HDI (soon to be HMS) in Region D set the pace with $152.7 million identified. The total for the quarter represents the highest quarterly number yet to be reported under the RAC program. When reviewing these regularly reported numbers, remember that these do not include completed appeals and, more importantly, do not include any estimate of the administrative costs to providers for every documentation request from the RACs that ends up going nowhere
Yet, there’s more to the story…
If you remember, in the final quarter of FY 2011, there were $76.6 million in underpayments identified, with Connolly, the Region C contractor, identifying $60.7 million from that total. Suddenly, we have evidence of a shift in strategy, as the combined total for underpayments plummeted to $24.9 million, with Connolly only identifying $2.6 million in underpayments in the last quarter. You’ll excuse the provider community in Region C for their muted response to this bit of news.
One other issue involving RACs that has come to the surface of late has to do with the MACs taking over the demand letter process. For many months, RAC coordinators nationwide, especially those affiliated with hospital systems stretched across many miles, worked diligently to centralize RAC correspondence under one address. Thanks to the Healthcare Integrated General Ledger Accounting System (HIGLAS) not being able to store more than one address per provider number, all of that hard work has now been undermined. All demand letters are now going to the payment address for the facility in question.
This opens up multiple cans of worms. If the RAC coordinator now has to flag down demand letters from several locations, any dreams of opening up a discussion period within 40 days begin to disappear. This is ironic, in that CGI, the Region B RAC, publicly stated at an outreach session in Wisconsin recently that they would like to see providers request discussion periods more than they currently do, based on the numbers in the region being low. Given the new hurdles encountered with demand letters, it’s hard to see how CGI gets their wish on that count.
Second, appeals that are now filed prior to recoup on the 41st day after the date on the demand letter will drop dramatically. Any savings that CMS may have hoped to gain from this fact is negated by two realities, one being the 10.5% interest rate every 30 days on successful provider appeals, and the other being the fact that providers are winning a lot of RAC appeals.
Finally, my e-mail inbox has been lighting up today regarding an imminent and (once again) temporary fix to the Sustainable Growth Rate cuts set to take hold on March 1st. The Deal of the Moment delays the scheduled cut until January 1, 2013 (a full 20 days after the scheduled Mayan Apocalypse), when physicians will face a cut of 35% if SGR has yet to be repealed by that time. The money for this latest desperate edition of the extension is coming mostly from reductions in Medicaid spending.
It has been a busy Leap Year February. I now happily leave you to the audit wolves for a fortnight.
The RAConteur will not appear next Wednesday, February 22nd. It will return on February 29th. In the meantime, consider meeting Paul Spencer live at the Fi-Med RAC Summit on April 16th and 17th in Milwaukee. Visit the Summit website for further details.