Recoupment of Federal Healthcare Dollars: Different Approaches
A Comparison of the Medicaid and Medicare Recovery Audits
While the words “fraud and abuse” may have diminished in use, they have been replaced with the latest catch phrases “improper payments” and “recovery audits.” Both Medicare and Medicaid are active in their efforts to remain true to their agency’s survival during this financial crisis through the audit processes.
 
While we are on the front end of the audit implementation, it is a good time to compare the nuances of the audits and better prepare ourselves for addressing time lines, audit issues and appeal processes for the federal agencies. But don’t forget, OIG audits and third-party payer audits are not going away. Everyone is enforcing their agendas as providers try to maintain their revenue cycle daily activities and keep up with audits.
First, the similarities between all the various payer audits that providers are juggling are less daunting than the differences, so let’s start easy with a comparison.
 
Table 1 delineates the similarities while Table 2 notes the basic differences. However, please note that these are not the only comparisons.

Similarities between MICs and RACs

RACs MICs
Notification of selection for an audit comes in the mail with a specified number of days to respond. Extensions are possible. Same
Data Mining is used on at least some of the audits in selecting the particular issue or claim to review. Same
All providers- not just hospitals or physicians - who submit claims to this payer, are eligible for audit. Same
Providers have the right to appeal the decision. Same
CMS has contracted with firms to carry out the audits. Same

Table 1

Differences between RACs and MICs

RACs MICs
RACs are mandated to post approved issues and time lines and to reach out to providers with proactive education on the issues. MICs have no mandate for provider outreach, however they do have remedial “education MICS” gearing up for implementation in 2010. They have posted a number of desk audit examples ranging from hysterectomies on males, DRG assignments and debridements. These are state specific.
There are 4 Recovery Audit Contractors and 2 RAC subcontractors who will oversee specified regions (A-D) of the country. Each of the RACs will perform financial recovery audits for over or underpayments. There are two types of audits: 1) Automated Audits 2) Complex Audits There are 5 Medicaid Integrity Contractor jurisdictions each covering 2 CMS regions. There are 3 primary types of MICs: 1) Review MICs 2) Audit MICs a) Desk Audits b) Field Audits 3) Education MICs
RACs are reimbursed on a contingency fee basis. MICs are eligible for bonuses based on their effectiveness and efficiency.
RACs will not look at claim that has been previously audited by any CMS entity. MICs exclude previous State audits and will not interfere with potential law enforcement investigation.
The appeal process is consistent nationwide. The appeal process is based on state guidelines.
RAC look back period is 3 years. MIC look back is based on the particular state guidelines.
RACs allow providers 45 days to produce medical records and pays 12 cents per page for copying. MICs will give providers up to 14 days (extensions are available if requested) to produce the medical records. There is no payment for copying the records.
The number of records reviewed is limited to 200 for the RAC audits. There is no record limit for MICs.

Table 2

While many are developing home grown electronic tracking tools in order to avoid missing deadline and others are purchasing audit software from vendors, the OIG and various insurance companies are surprising all of us with their random audits and requests. 
 
Remember the old saying that the devil is in the details? In the case of RACs and MICs, it truly is the little things that can result in major problems that haunt us. 

Needless to say, there are many, many comparisons that could be explored on the topic of auditor guidelines and specifications and we have only addressed a baker’s dozen. No doubt we need to re-address RACs and MICs toward the end of the year when we all have had a chance to experience them live.
 

Betty Hatten is a manager in health care services at HORNE LLP. Her primary responsibilities include oversight of the chargemaster assessment and maintenance team, as well as providing charge capture audits, performance improvement assessments, and focused compliance reviews. Betty is a frequent seminar presenter and customizes presentations for clients, hospital associations, and professional organizations on the local, regional, and national level. 
HORNE is one of the top 50 accounting and business advisory firms in the country, as reported by both Public Accounting Report (PAR) and INSIDE Public Accounting (IPA), and one of the top 10 accounting and business advisory firms in the Southeast. With 13 offices in Mississippi, Tennessee, Alabama, Louisiana, Arizona and Texas, the firm has more than 475 team members serving clients across the nation. For more information on HORNE LLP, visit www.horne-llp.com
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