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It was early June 2010 when calls from customers started coming in. First one record was missing. Then several records were missing and finally 7 charts had simply vanished within Connolly Healthcare. Despite having a confirmed tracking record from Federal Express with signature on file and time of delivery, the message from Connolly was clear: resubmit the records or face unwarranted denials.
Just when RAC reviews seemed to be going smoothly, HIM directors and RAC coordinators got hit with an additional step in submitting records and processing appeals. It now appears that we also have to track the RAC!
Tracking the RAC
What started with Connolly Healthcare has been reported with other RACs as well, including CGI Technologies and DCS. Receiving and quality control processes appear to be faulty and inconsistent. Receiving records is not a strong skill for the RACs.
In some cases, records were boxed and sent in bulk. Some records were received but others were not. In another case, the RAC simply replied that they could confirm receipt of the Federal Express package, but suggested that it had been sent empty. Their rationale, "just because you have a verifiable receipt, it does not mean a record was sent."
After the problem of missing records was reported by several hospitals, Jonathan Arkin, vice president, HealthPort, placed an immediate phone call to the CMS RAC project manager for Connolly and was able to effectively win the battle on behalf of the effected hospitals.
The CMS RAC project manager agreed that if providers can show records were sent and received, they will not have to be reprinted. And RACs will be forced to close their review of such claims. At this point in time, this position is confirmed for Connolly only. Providers will have to stay tuned to see how the other RACs respond.
What to Do, How to Respond
It is a waste of time and money to send every requested record separately. However, it's also costly for providers to go back and fight to prove records were sent on time via a verifiable means and confirm receipt. While the RACs respond and improve their processes, there are several important steps providers can take.
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Check the RAC website within 5 business days of sending records; if it does not document receipt, start calling them.
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Gather tracking documentation from Federal Express or other verifiable delivery means.
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If there is failure to get a resolution from the RAC or they insist you resubmit records, contact the CMS RAC project manager.
The RACs cannot demand you resubmit records if you have proof that the records were previously sent and receive by them. Keep the proof and keep pushing your complaints upwards to CMS.
Technology Solutions Ahead
For now, this additional step is both a frustration and time waster for hospitals. The last thing providers need is another checkpoint in the process. However, being proactive is currently the best response. Future solutions should include the use of technology to automatically query RAC databases and flag discrepancies in record receipt, thereby alerting HIM directors and RAC coordinators of missing charts. Necessity remains the mother of invention!
Lori Brocato is audit and RCM product manager for HealthPort.
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