David Harlow quoted in Part B Insider piece on RACs

The OIG recently reviewed RAC performance to date in identifying fraud (vs. overpayment) and found the RACs wanting.  To be fair, the RACs haven't been trained in identifying Medicare fraud. Part B Insider asked me how providers should prepare for an encounter with a RAC (a "RAC attack"?) and my answer is consistent with what I advise providers on a regular basis:  Be prepared.  Be proactive. 

“From my perspective, it is always better to conduct regular internal reviews as part of robust standing compliance and internal audit programs,” Harlow says. “If these compliance reviews and audits are carried out thoroughly, the results may be used in challenging or appealing RAC reviews.”

When applicable, providers should initiate self-disclosure of fraudulent billing uncovered by internal compliance reviews and audits, in accordance with the OIG’s voluntary self-disclosure protocol, Harlow says. “Doing so should eliminate the imposition of a corporate integrity agreement — which carries with it significant costs, both in terms of ongoing monitoring and compliance, as well as negative publicity.”

Read the rest of the piece on RACs and how to protect your practice. 

David Harlow
The Harlow Group LLC
Health Care Law and Consulting