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What should I do to protect my practice from RAC recovery efforts?

Most importantly, continue or implement ongoing compliance activities within your practice, including all staff from schedulers to physicians.
  • Educate staff to recognize and efficiently handle all requests for records from a RAC or other program integrity contractor with a structured protocol and log. Before copies of records are sent to a RAC, be sure that all information related to a service has been included (e.g., If you reference patient history collected on a questionnaire, include a copy of the questionnaire.).
  • Maintain an awareness of services targeted by the Office of the Inspector General’s work plan, services with high error rates found by Comprehensive Error Rate Testing (CERT) contractors, and services with very high utilization or cost. Focus of the RAC’s include consultations, E & M services on the same date as a procedure, global periods, services provided incident to a physician’s services, and relationships between a physician certifying durable medical equipment and the supplier of the durable medical equipment.
  • Make sure that documentation is clear and complete for all services, including the date, signature, and credentials of the person ordering and /or providing the service (e.g., documentation of injection order by nurse practitioner and administration by medical assistant).
  • If you do not have a designated compliance officer, this is a good time to designate and assign duties aimed at protecting your practice from errors and omissions in your practice’s billing, coding and documentation. This person may also take the lead in logging and responding to records requests and/or refund requests received by the practice.
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