Yesterday, the Heart Rhythm Society (HRS) submitted a written testimony to the Senate Committee on Finance to share its views on Recovery Audit Contractors (RACs) in the Medicare Program. HRS provided comments regarding the regulatory burden associated with the Centers for Medicare and Medicaid Services (CMS) program integrity activities that negatively impact physicians and physician group practices.
The intention of yesterday’s testimony was to present specific recommendations to the Senate Committee on Finance that may improve the RAC program and help alleviate the audit burden impacting both hospitals and physicians. While the “Medicare Audit Improvement Act of 2013,” a bill supported by HRS, seeks to improve hospital audit program integrity issues, HRS also calls for improvement to the RAC program as it affects physicians in addition to its impact on hospitals.
Through the written testimony, HRS sheds light on key audit issues affecting physicians :
(1) The frequent occurrence of unnecessary, costly and lengthy audits that result from interpretations of medical necessity that are based on outdated and incongruent criteria;
(2) The lack of transparency in auditor activities, including sampling and extrapolation methodologies; and
(3) The paucity of education on common coding and billing errors and omissions, and associated education on avoiding such mistakes.
The inconsistencies that exist between the national coverage determination requirements (NCD) and current standards of care results in the auditing of physicians who are adhering to evidence-based medical practices. These discrepancies often create costly and potentially unnecessary investigations.
HRS urges the Committee to undertake comprehensive legislation to address both hospital and physician concerns, including the following physician-focused recommendations: maximum documentation requests, audit performance requirements, transparency of auditor activities, physician review for Medicare denials, appropriate use of Medicare rules and regulations, education and technical assistance and regular review of local and national coverage determinations.
HRS anticipates that legislative efforts will balance the imperative to audit for fraud and abuse without increasing the burden on physicians who are practicing evidence-based medicine in the best interest of Medicare beneficiaries. HRS looks forward to working with the Committee, other medical societies and key stakeholders to address these issues.