"Physical therapy is not a subspecialty of the medical profession and physical therapists are not medical doctors; we are a separate profession that provides a unique service that physicians are unable and untrained to provide."

Letter to the AMA from the APTA, Dec 2009

Thursday, December 4, 2008

Medicare RAC nightmare

I woke last night, sweating and afraid.

I felt my heartbeat pounding in my chest.

I had a nightmare.

I think I cried out because my wife woke, mumbled something and reached out to pat my leg.

In my nightmare, Medicare Recovery Audit Contractors (RAC) were in my PT clinic threatening hefty fines and jail time.

Paper lay in piles all over my office. Charts were open and strewn about on desks.

Copy machines hummed and glowing lights illuminated stern-faced auditors with green eyeshades.

"You're in a lot of trouble Mr. Richardson, did you know that?"

Of course, it was just a nightmare.

I wasn't actually being audited by Medicare RACs.

Some private practice physical therapists may share my anxiety.

For us, the threat of a RAC audit looms large as the expected February 2009 nationwide RAC roll-out approaches.

So what, in the bright light of day, are the known risks of a physical therapist RAC audit?

Here are some of the resources I have compiled to help physical therapists understand RACs.

Hint: It's not all bad.


Medical Necessity

Who gets caught?

Advance Beneficiary Notice

Patient Case

RAC expansion schedule

RAC Fact Sheet

OIG Work Plan

Bulletproof Physical Therapy Notes and Charts


  1. The Centers for Medicare & Medicaid Services recently released the transcripts of the November 2008 Special Open Door Forums on the Medicare recovery audit contractor program. See the Medicare Update weblog’s post at http://tinyurl.com/8cm9xd

  2. Michael,

    Thanks for your link.

    I've been to your blog and linked to your work on occasion. You are a terrific resource on RACs and Medicare audits.

    One premise I make in my blog, Physical Therapy Diagnosis, is that RACs have the same criteria for audit recovery as MACs.

    To what extent is there any justification for a small group or solo practice to expand or change their existing Medicare compliance program based on 'RAC anxiety'.

    I encourage all providers to have an updated compliance plan and I wonder what you would advise providers to do differently based on the RACs actions?


    Tim Richardson, PT

  3. Great post you got here. It would be great to read a bit more about that topic. Thanks for sharing this information.


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Tim Richardson, PT owns a private practice at Medical Arts Rehabilitation, Inc in Palmetto, Florida. The clinic website is at MedicalArtsRehab.com.

Bulletproof Expert Systems: Clinical Decision Support for Physical Therapists in the Outpatient Setting is a manager's workbook with stories, checklists, charts, graphs, tables, and templates describing how you can use paper-based or computerized tools to improve your clinic's Medicare compliance, process adherence and patient outcomes.

Tim has implemented a computerized Clinical Decision Support (CDS) system in his clinic since 2006 that serves as a Reminder, Alerting, Prompting and Predicting CDS using evidence-based tests and measures.

Tim can be reached at
TimRichPT@BulletproofPT.com .

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