Magdalena Falcon-Law, BS, RN1, Patricia Griffin, BS, RN1, and Vincent Maher, JD, MA, MS2. (1) Department of Health Care Programs, Iona College, c/o Maher, Hagan School of Business, Iona College, 715 North Avenue, New Rochelle, NY 10801, (2) Health Care Programs, Iona College, 715 North Avenue, New Rochelle, NY 10801
Years of ever increasing healthcare costs have prompted the Centers for Medicare & Medicaid Services (CMS) to decrease and streamline healthcare costs and services. CMS has implemented programs such as quality care improvement measures, (so-called pay-for-performance measures) designed to reward health care providers for reporting specific quality measures of their care. The hope is that improved quality care will provide improved patient care, and thus save CMS money over time. A more direct approach at cost containment has been found in the Recovery Audit Contractor (RAC) program. As a mandate from Congress, the RAC program was designed to reduce improper payments within the Medicare programs as well as identify process improvements to reduce or eliminate future improper payment. The states of New York, Florida, and California were the first states selected to participate in the demonstration project. The project began in 2005 and ended in 2008. CMS awarded the contract in New York to Connelly Consulting, in Florida to Health Data Insights, and in California to PRG-Schultz. The evaluation report indicates that $693.6 million dollars in improper Medicare payments were returned to the Medicare Trust Funds between 2005 and March 2008. The funds returned are said to have occurred after taking into account the dollars repaid to health care providers, the monies overturned on appeal and the costs of operating the RAC demonstration project. Based on these significant findings and substantial amounts of monies returned, CMS plans to roll out the program in all fifty states. The RAC program also monitors underpayments as well.
This CMS initiative asks the question, what are health care facilities doing to ensure that their billing and coding practices result in kept monies? It is imperative that in these economic times Health care organizations continue providing patients with quality health care and still meet their fiduciary responsibilities. Another important question is whether on not the RAC is as zealous finding underpayment as they obviously are at finding overpayment. The RACs are paid a contingency fee, receiving payment based on the amount of the improper payments they correct for both overpayments and underpayments. Each RAC's contingency fee is established during contract negotiations with CMS. The contingency fee varies for each RAC. Documentation improvement (DI) programs might well be the answer in assisting healthcare facilities during these economic trials. These DI programs assist physicians in documenting the patient's diagnosis to the highest degree of specificity. These diagnoses are supported by the care provided to the patient, thus rendering a well documented medical record. These medical records, illustrate the quality of care provided to the patient, and are therefore able to withstand a RAC review.