New Limits on RAC Requests to Physicians, Other Practitioners

New limits have been placed on the maximum number of medical records a recovery audit contractor may request from physicians and non-physician practitioners for complex reviews, according to a release from CMS.

1. Number of entities. To qualify as a single entity for such requests, a practice must have only one tax identification number. And if the practice has more than one location, the first three digits of the ZIP codes at all locations must be the same to quality as one entity. Otherwise, the practice will be seen as more than one distinct entity for purposes for RAC requests.

2. Size of practices.
The number of records that RACs may request from each entity in a 45-day period depends on the number of physicians or other practitioners at each entity. RACs may request a limit of 50 records from a group of 50 or more practitioners; up to 40 records for a group of 25-49; up to 25 records from a group of 6-24; and up to 10 records from a group of five or fewer.

3. If RACs exceed limits. If a practice receives a request for more documents than the guidelines would allow, it may request the RAC to modify the limit and provide documentation of its size.

4. RACs may exceed limits.
CMS may give a RAC permission to exceed the limits, even without a request from the RAC. Affected practices will be notified of the change in writing.

Read the CMS release (pdf).

Read more coverage of complex reviews by RACs:

- 18 Findings from the Latest AHA Survey on RAC Activity

- Differences Between RACs' Automated and Complex Reviews

- 8 Steps to Mastering Audits by RACs, Other Agencies


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