RAC Complex Reviews to Arrive as Soon as August

The new information is consistent with CMS' previous indications that some providers may begin to undergo automated review this month.

According to the CMS, the earliest possible dates for RAC reviews in yellow and green states are:

• June 2009—Automated reviews of black and white issues


• August or September 2009—Complex reviews for DRG validation


• August or September 2009—Complex review for coding errors


• Fiscal year 2010, which begins October 1, 2009—Complex reviews for durable medical equipment (DME) medical necessity


• Calendar year 2010—Complex reviews for medical necessity

The earliest possible dates for reviews in blue states generally fall a bit later:

• August 2009—Automated reviews of black and white issues


• October or November 2009—Complex reviews for DRG validation


• October or November 2009—Complex review for coding errors


• Fiscal year 2010—Complex reviews for DME medical necessity


• Calendar year 2010—Complex reviews for medical necessity

CMS also reaffirmed that before RACs actively begin auditing in a particular state, outreach educational sessions must occur in that area.

Although the schedule calls for automated reviews as early as this month, any issue a RAC reviews must be vetted through the CMS' "Issue Review Board." In addition, RACs must post the approved issues to their Web sites before the reviews can begin.

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