There are times in my life when excessive quiet is unwelcome. Living two blocks away from a major metropolitan hospital is a challenge to the sleeping habits of others, but as a person who went to sleep this morning just after 3 AM who subsequently awoke around 7 for work, ambulance sirens have no effect on my sleep patterns.
There is one area of the government audit universe that has maintained an eerie quiet in 2012, despite the fanfare that accompanied its creation. The Medicaid RAC program, already harboring a secondary implementation date of January 1, 2012, continues to be plagued by delays in certain states. Yet through the silence, anecdotal evidence is beginning to filter out that the Medicaid RAC program has begun in earnest.
To date, information has reached me from two human sources that Medicaid RAC audits have begun in three states: Connecticut, Kansas and New Jersey. I am attempting as best as I can to determine what audit issues are being reviewed in these states, but I can relate that all three of these states have one thing in common.
HMS, who has emerged as a major player in the Medicaid RAC universe, is the Medicaid RAC for New Jersey and Connecticut. Kansas, which was the first state nationally to enlist a Medicaid RAC, has HDI, the Region D Medicare RAC contractor and a subsidiary of HMS as of late in 2011.
To date, HMS is the finalized or intended Medicaid RAC contractor or subcontractor in 18 states, with HDI handling Kansas under HMS’ corporate umbrella. For providers of all types, I would fully expect that Medicaid RAC activity will soon begin in the following states under HMS’ purview: Alabama, Delaware, Indiana, Maine, Michigan, New Mexico, New York, Oregon, Pennsylvania, South Carolina and Tennessee. These states all have finalized contracts with HMS, and based on its activity in Connecticut and New Jersey, it is reasonable to expect that the remainder of the dominoes will soon begin to tumble.
There are two states worth mentioning that are so far behind the Medicaid RAC curve that the futures of their respective programs is in doubt. In Arkansas, a Request for Proposals (RFP) for a RAC contractor was originally released in April of 2011. The responses to the RFP were of such a poor caliber that the state has declined to enter into a RAC contract. A similar situation exists in Texas, where CGI, the Region B Medicare RAC contractor was originally awarded the Lone Star State’s contract, but the contract was later withdrawn. Texas later issued a new RFP, but this was also withdrawn on May 8th.
Out West, Wyoming, Idaho, Montana and Utah continue to pursue a four-state solution for their RAC activities. Meanwhile, Minnesota and Wisconsin are considering the same type of group arrangement for Medicaid RAC issues here in the Upper Midwest.
Clearly, with so many states not mentioned above, it is safe to say that the balance of the states are operating in an eerie silence as the provider community awaits first contact with the Medicaid RAC process. At that future point in time, the sound of an ambulance siren will be somewhat redundant.
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