10 Tips on Improving RAC Readiness From Kaiser's RAC Expert

Writing in the RAC Monitor, Gloryanne Bryant, regional managing director of health information management for the 21 Kaiser Foundation and Hospitals in Northern California, provides the following 10 tips to improve readiness for recovery audit contractors.

1. Be proactive, not reactive. Every institution is aware of areas that need improvement. "We all have had audits conducted, heard from our staff and received denials, and thus we know where there are weaknesses and vulnerabilities to which we can respond," Ms. Bryant wrote.

2. List risk areas. Using information from past audits, your RAC committee should compile a list of risk areas that demand attention. Another way to be proactive is to check your RAC's website a couple times a week. "The mail doesn't always get delivered in a timely manner, and we need to know about requests as soon as possible," Ms. Bryant wrote.

3. Think like a RAC. Ask yourself: "If you were a RAC, what targets would you focus on, and where would you do some data mining?"

4. Identify Gaps. Auditing orders from admitting physicians and compliance with medical necessity is essential and can be used as a RAC defense. The work could involve auditing or monitoring case management or utilization review as well as criteria used to validate medical necessity. Be sure to keep up with ongoing audits and follow up with corrective action plans, establishing timelines and education of staff.

5. Other areas to look at. Examine documentation and coding of outpatient wound care, interventional and cardiac interventional radiology documentation and coding, the practice of auto-charging via Charge Description Master without documentation linkage, and compare coding of professional with hospital coding for the same services.

6. Identify Underpayments. Issues might include inpatient patient status codes involving discharge disposition, missed comorbidities/complications and major comorbidities/complications, and Hierarchical Conditions Categories - Part C.

7. Use IT systems. Use your electronic health record to improve documentation and your computer-assisted coding to provide some answers and solutions to the problems already listed.

8. Keep track of other RACs. Keep track of RAC activities in other regions. Review the other RAC websites regularly, read articles on RACs and expand your understanding of all RAC activities.

9. Monitor all DRGs. "We now know that nearly all DRGs are listed as potential risks, so this means both medical necessity and coding need greater oversight, auditing, education and monitoring," Ms. Bryant wrote. Also review published plans for future RAC activities to understand upcoming scrutiny of Medicare Part C and D.

10. Monitor other auditing programs. Your RAC tracking tool should cover other auditing activities, such as Comprehensive Error Rate Testing, Zone Program Integrity Contractors and Medicaid Integrity Contractors. Know who they are before they come knocking.

Read Mr. Bryant's article in the RAC Monitor.


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