The RAC gun.
The Medicare Recovery Audit Contractor (RAC) program is a new permanent federal program expected to 'go live' in February 2009.
The initial roll-out is mainly in the northeast and in the RAC demonstration states.
I live in Florida, a demonstration state since 2005.
Recent conversations I've had with my peers and professional organizations indicate that there is a lot of additional anxiety regarding the RACs.
While I never want to downplay the severity or the possibility of a Medicare audit, MAC or RAC, I want to present some information that can help private practice physical therapists assess the risk of and the damage from the RACs.
| RECOVERED AMOUNT | NUMBER OF PROVIDERS | TOTAL PHYSICIANS AUDITED BY RACS: 2005-2008 | |
|---|---|---|---|
| My experience: 2005-2008 | ~$80 | 7 | |
| Average Florida Provider: 2006 | $135 | 21,927 | |
| Average California Provider: 2006 | $216 | 50,054 |
Data for this table is available in this report.
Note that physical therapists are lumped in with physicians in the RAC report from which this data is drawn.
$992.7 million dollars in overpayments were recovered from providers, mainly (85%) inpatient hospitals.
Of the $992.7 million only $19 million came from physician practices (which include physical therapists).
40% ($391.3 million) of the overpayments were for medically unnecessary services.
Services are medically unnecessary when the clinician failed to justify why the services were performed.
For physical therapists this usually means measurements of ROM or strength deficits.
Also, measurements of activity limitations.
Finally, link deficits to activity limitations in the physical therapists' diagnosis.
Bulletproof Compliance
Your current Medicare compliance plan should be sufficient to respond to a RAC audit.
If you have a current Medicare compliance plan.
Mine used to be a dusty manila file folder sitting up on a shelf.
Not anymore.
I got busy and got some basic education - available in this blog and at Bulletproof PT.
Get your own compliance program.
Get Bulletproof.
I live under the gun...
But, I sleep well.
