Most of the RAC activity is targeted at the largest cost centers - that is, the hospital.
Beginning April 1st, however, small practice physical therapists that fall under the Medicare Part B $3,700 cap on physical and speech therapy will face RAC audits. The RACs will be performing both pre- and post-payment audits for the manual medical review (MMR) process.
RACs typically cite medical necessity as their number one reason for denial of claims. Altogether, the program corrected $5 billion in faulty Medicare payments since it began in October 2009, according to CMS.
Click through this image below for the April 2013 RAC results to date:
|RAC result to date from the inception of the program in 2009|
The American Physical Therapy Association (APTA) has a page of resources for physical therapists who want to comply with RAC requirements (membership required). Check out this story at FierceHealthCare.com with additional links.
Tips to protect yourself from a RAC audit:
Educate yourself - the Florida Physical Therapists in Private Practice (FLPTPP.com) has a full day of educational programming May 18th, 2013 in Orlando, Florida geared towards recognition of risk and compliance with RAC audits, G-codes and the Manual Medical Review process.
Establish a compliance plan and conduct self-audits - hundreds of physical therapists have used this e-mail version of the Office of the Inspector General (OIG) Small Practice Compliance Plan to learn the steps - one of which is self audits:
Ensure follow-up - if you do get a RAC demand letter appoint one person in your office to immediately follow-up. You usually have a deadline, such as 30 days, to respond.