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McBrayer Blogs
Showing 2 posts in Recovery Audit Contractors (“RAC”).
CMS Ruling on Part B Rebilling
Posted In Centers for Medicare & Medicaid Services (“CMS”), Health Care Law, Medicare Administrative Coordinators, Medicare Benefit Policy Manual, Part A, Part B, Recovery Audit Contractors (“RAC”)
Increasingly, Administrative Law Judges (“ALJs”) and the Medicare Appeals Council were upholding Part A denials on RAC audit appeals based on determinations that inpatient admissions were not reasonable and necessary, and then ordering payment under Part B as if services were rendered at an outpatient or “observation level” of care. The problem with this practice is that Medicare Benefit Policy Manual (“MBPM”) allows hospitals to bill a Part B inpatient claim for only a limited set of medical and other health services. Additionally, the providing for payment of all reasonable and necessary Part B services under these circumstances are contrary to CMS policy that the services be billed within the usual timely filing restrictions. The Centers for Medicare & Medicaid Services (“CMS”), concerned about this practice, recently released both a Ruling and a Proposed Rule to seemingly help the hospital community. How much relief it will actually provide is yet to be seen. More >
Reforming Medicare Audits
Posted In Health Care Law, Medicaid, Medicare, Medicare Audit Improvement Act of 2012, Recovery Audit Contractors (“RAC”)
On October 16, 2012, the Medicare Audit Improvement Act of 2012[1] was introduced in the U.S. House of Representatives by Representative Sam Graves. The purpose of this legislation is to reform the Medicare auditing program. This legislation aims to improve the accuracy and transparency of Medicare audits of hospitals as well as increase the accountability of Recovery Audit Contractors (“RAC”).[2] More >
