RAC Program (Medicare Fee-for-Service) Record Request Limits Increased

Medicare released new guidelines regarding the limit on the number of additional documentation requests (“ADRs”) RACs may request per 45-day period. Notably, these revisions constitute an increase for providers. (Note: the revised ADR limits outlined below do not apply to physicians and suppliers.)

Effective March 15, 2012, the ADR limits will follow the guidelines bulleted below:

•RACs may request up to 2 percent of all claims submitted for the previous calendar year divided by 8 per 45 days. ** Note that this constitutes an increase from the previous limit of 1 percent of all claims submitted during the previous calendar year divided by 8 per 45 days.

•Notwithstanding the above, there will be a 400 record per-campus maximum ADR request limit (unless the provider previously was notified of an increased cap of 500 ADR requests – These providers will now have a cap of 600 records per 45 days).

•CMS may give the Recovery Auditors permission to exceed the limit. Permission to exceed the limit may occur by CMS’s own initiative or from the Recovery Auditor requesting permission. CMS or the Recovery Auditor will notify affected providers in writing.

The new ADR limits are available on the CMS RAC website at http://www.cms.gov/Recovery-Audit-Program/Downloads/Providers_ADRLimit_Update-03-12.pdf.

For more information on this topic, please contact Abby Pendleton or Jessica Gustafson at (248) 996-8510 or visit The HLP website at www.thehealthlawpartners.com.