Medicaid RAC Program Moves Forward Despite Delay

This article first appeared in RACmonitor.

While CMS' delay of Medicaid RACs came as a relief to state governments and Medicaid providers nationwide, it is important to be aware that work continues behind the scenes as CMS begins to approve state plan amendments for the Medicaid RAC Program.

On March 2nd, CMS debuted a website called “State Medicaid RACs At-A-Glance”. The site is in the form of an interactive map showing the progress of state plan amendment approvals by state. At the time of this writing, every state (as mandated) has submitted a state plan amendment for approval, with the majority of states having had their SPAs approved.

The map offers quite a window into how states are approaching their respective RAC programs. At the time of writing, nine states, mostly in the Midwest and Western portion of the country, along with all five US territories, have requested exceptions from the Medicaid RAC program in addition to submitting a plan amendment. The Medicaid RAC proposed rule stated that exceptions would only be granted “rarely, and only under the most compelling of circumstances”. It remains to be seen whether the requests for exceptions from these areas will be granted.

The Medicaid RAC proposed rule referenced the contingency fee structure currently utilized by the Medicare RAC program. The new site shows that of the states that have identified RAC fee structures, all of them are following the Medicare RAC model. Additional checking shows that there is no correlation between states that have requested an exception from the program and the type of contingency fee structure created by the SPA.

With all of this information now offered in one place, there is one notable piece of information missing from this site. The RAC contractors that to this point have signed contracts with individual states to provide services are not identified. Back in February, acting upon my unending curiosity, I contacted Angela Brice-Smith, the director of the Medicaid Integrity Group at CMS, asking whether such a listing would become available. According to Ms. Brice-Smith, CMS “is working on a transparency initiative to provide greater information to the public on the progress the states are making to establish and implement Medicaid RACs”. While the At-A-Glance website can be seen as the beginnings of this initiative, the listing of RAC contractors by state remains pending at this time.

The Final Rule for the Medicaid RAC program is expected to be released sometime later this year. Since its introduction, the At-A-Glance website has been modified as new information has become available. It is recommended that the site be bookmarked for future updates as the Final Rule is under construction.  

Related Articles on Medicaid RACs:
Who Are the Medicaid RACs?
Senator Faults CMS for Postponing Medicaid RACs
New Website to Show Status of Medicaid RACs

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