CMS released a short but useful Recovery Audit Contractor
(RAC) update on its website last week reporting the total amount of improper
payments identified since the RAC demonstration period.
From October 2009 through the end of March 2011, RACs
identified $312.2 million in overpayments and $52.6 million in underpayments,
totaling $365.8 million in improper payments. Compared to the $1.03 billion of
improper payments identified in the demonstration program, these numbers are
minuscule, but a significant bump last quarter may indicate significant growth
is on the way.
The doubled amounts ($184.6 million) in the first quarter
of 2011 is a true reflection of the rapid expansion of RAC audits.
In addition to the identification of total improper
payments, CMS also highlighted the top RAC issue per RAC region from the fiscal
year 2010 through March 2011. Incorrect coding causes two of the four issues
identified. The others are caused by billing for bundled services (DME provided
during an inpatient stay) separately, which should trigger providers to
investigate a potential area of vulnerability.
Providers need to be paying attention when they have
separate national provider identifiers (NPI) that are providing various pieces
of services and billing Medicare separately.
We will keep you updated as CMS comes out with other
potential areas to improve on and be made aware of as causes for incorrect