is an important preparation tool as internal audit results can show where
additional education and training are needed. Self-auditing should also be used
when determining whether your staff is appropriately coding, billing, and
Recovery Audit Contractors
are looking for errors. CMS has stated that only one type of self-audit will
ensure RACs may not later review the claims, and it probably is not the kind of
self-audit you are used to.
The type of self-audit you are probably used to is a Voluntary
Refund audit. This type of self-audit is claim-based. If
the required information is included along with the amount of the improper
payment, the claim will be adjusted by the claim processing contractor. The RAC
will be aware of the adjustment, but the refund does not preclude
In an Extrapolation Audit, past
historical data is used. The claim processing contractor will review the case
file to determine if it is acceptable. The claims processing contractor will
accept or deny the extrapolation for the issue you identified. If the claim
processing contractor accepts the extrapolation, those claims
will be excluded from RAC review.
What does this mean? If you use an extrapolation that is
accepted by your Medicare carrier, the claims are off-limits for RACs.
Otherwise, individual claims corrected after a self-audit are not immune.
If you review your claims, you may feel a little less
incentive to report errors and over-payments that you discover since the claims
are not protected from RACs, but not doing so is a compliance problem.
Ignoring a false claim is never a good idea.