Since this happens to be a year when a presidential election occurs, we can expect that over the next 10 weeks, we shall be subjected to well-choreographed and carefully-tested speeches that refer to what makes the United States “the greatest country in the world”. To save everyone some time for other more wholesome activities, let me give you the correct analysis of this question.
America, more than any place on Earth, offers above all things the possibility of re-invention. In the simplest terms, we are a collection of the refuse from the rest of the world. All of us ended up here because either ourselves or our ancestors were precipitously close to the bottom of life’s ladder somewhere else. As an example, one of my great-grandfathers on my mother’s side left the British Isles, where he was a simple alcoholic, and came to America, where he rose to the level of employed and thriving binge drinker. Three generations later, you all get this blog.
One unique quirk about our system is that the possibility of re-invention never ends once you get here. Nowhere is this more apparent than in the business world. If people associate the name R. J. Reynolds with deadly tobacco products, no problem. They can just change their name to ALTRIA, which is a field-tested, nondescript word that doesn’t make people think of lung cancer. If medical billing company Medaphis finds itself under an OIG corporate integrity agreement, no problem. They can call themselves Per-Se Technologies and start again. I once asked my good friend and compatriot Curtis to describe America in five words or less, and he said “Cosmetic surgery”. Maybe this is what he was talking about?
This month, the wheels of re-invention struck the RAC world, when DCS, the Region A RAC, announced that they had changed their name to Performant Recovery, Inc, “a subsidiary of Performant Financial Corporation”. Performant has been a government contractor performing various collection activities for federal programs since the late-1990’s. Federal contractors never truly go away…..
This particular name change is not a quest for sudden anonymity that comes with finding that you have been knee-deep in questionable activity, such as Altria and Per-Se. Yet if there is any process in the realm of healthcare that would benefit from a dark cave and a disguise, none is more in need than the recovery audit process.
CMS has repeatedly stated that the RAC effect on administrative burden should be minimal. It would be extremely hard to make that argument to hospital systems, some of whom have had thousands of additional documentation requests. It is equally impossible to make that argument to administrative law judges around the country, who are beginning to grouse about the rapid expansion of the number of RAC appeals on their dockets.
Sometimes, reinvention takes more than either a change of scenery or a simple name change. It takes a renewed commitment to performing tasks that are of benefit to society at large. When rural hospitals are threatened with extinction due to predatory recovery practices, which forces choices between patient care and administrative activities, a RAC by any other name is still a RAC.
This particular attempt at reinvention is more akin to the federal witness protection program. A gangster in a small town under an assumed name is still a gangster, and your presence and way of doing business, in any form, is not appreciated.