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HealthDataInsights (HDI) is the second of the four Recovery Audit Contractors (RAC) to post approved CMS topics for review. All the topics posted are in the category of Outpatient Hospital and Physician Services and cover all 17 states and 3 territories in Region D. The list of topics is exactly the same as posted by Connolly (Region C) the previous week.
Now is the time to implement routine auditing of your billing to detemine if any untimed codes were billed in units of more than one. This topic will be discussed at the NARA Fall Conference by Nancy Beckley. Register for the NARA Fall Conference here.
The Recovery Audit Contractor program is now in full swing. Connolly Healthcare, the RAC Contractor for Region C posted on its website the first CMS approved issues that have been approved by for review. The RAC approved issues are approved for hospital outpatient and physicians and include blood transfusions, untimed codes, IV hydration therapy broncoscopy services,once in a lifetime procedures,pediatric codes exceeding age parameters and J2502 injection pegfilgrastim6 mg.
The first set of approved issues includes outpatient rehab in the mix, and the source of the issues comes straight from the finding in the RAC demonstration project in California and New York.In the demonstration project $3.2 million of claims for speech evaluation were found to be billed in error as time-based codes, rather than as service-based codes. The Speech evaluation code may only be billed as a unit of "1". The same is also true for physical therapy evaluation and occupational therapy evaluation codes.
To get ready for this type of review determine if you have billed evaluation and/or service based codees in error. If your audit determines that there are billing errors determine under your compliance program the process to be followed in making a voluntary refund, or if a self-disclosure is warranted. If you believe that you have problems it would be wise to conduct your audit under attorney-client privelege.
The wording of the Connolly RAC CMS approved issue on "untimed codes" is as follows:
- Issue Name: Untimed Codes
- Description: CPT Codes (excluding modifiers KX, and 59) where the procedure is not defined by a specific timeframe (untimed codes), the provider should enter a one (1) in the units billed column per date of service.
- Provider Types Affected:Outpatient Hospital and Physician
- Date of Service: 10/01/2007 - Open
- States Affected: South Carolina
- Additional Information: Additional information can be found in the following manuals/publications:
The map below lists the RAC contractors as well as the revised phase-in schedule. RAC can begin the work process following the completion of the 'town hall" meetings that began this spring. Conolly was the first to roll out these town hall meetings in South Carolina and Florida, so expect topics for Florida, New Mexico and Colorado presumably to be announced shortly.

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