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RAC Frequently Asked Questions Updated

Following The HLP’s submission of numerous written inquiries and phone calls to representatives of CMS, National Government Services, Inc. (“NGS”) (the Medicare Affiliated Contractor), and CGI (the Medicare RAC for Region B), on November 8, 2010, CMS published a response to Frequently Asked Questions related to RAC reviews of Periodic Interim Payments (“PIP”). As described by CMS, PIP are “biweekly payments made to a provider enrolled in the PIP program based upon the hospital’s estimate of applicable Medicare reimbursement for the current cost report period.”

Confusion had arisen among hospitals with respect to the appeals process for PIP claims. Specifically, because “Review Results Letters” were being issued, but “Demand Letters” were not consistently being issued (but sometimes were issued), it was unclear what event would trigger appeal rights with respect to PIP claims.

Pursuant to the recently-posted FAQ, the “discussion period” for PIP claims is initiated by the Review Results Letter. The RA establishes appeal rights for PIP claims. Accordingly, a hospital that has received a PIP claim denial should monitor incoming RAs for the PIP-claim adjustment, as such event will trigger any appeals time frames.

For more information regarding RACs, please contact Abby Pendleton, Esq. or Jessica L. Gustafson, Esq. at (248) 996-8510.

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