RAC

We have officially received our first letter from RAC. Has anyone had the experience of a CDS reviewed chart that is audited by RAC?

Comments

  • edited May 2016
    What region are you in? Was it for an automated review or a complex review?

    Debbie
  • No, we've not received any RAC requests yet.
  • edited May 2016
    Region A. Automated this time. It is the complex reviews I am worried
    about

    Thank you,
    Susan Tiffany RN, CDS
  • edited May 2016
    We had received a request for 87 records for complex review.
    I am in the process of reviewing all of those records to get a handle on our actual level of exposure.

    I will be looking back from the perspective of whether or not the case was reviewed by CDI and then if a query was involved with the likely flag or if there was a risk we could have diminished if we had intervened -- but haven't looked at that aspect as of yet.

    There was one clear pattern -- all of the 20+ spepsis with MCC cases were all 1-2 LOS (not including day of discharge), no expired pts.
    Don't see any clear pattern with the extensive / non-extensive procedures unrelated to pdx as of yet.

    Don

    Donald A. Butler, RN, BSN
    Manager, Clinical Documentation
    PCMH, Greenville NC
    dbutler@pcmh.com
  • edited May 2016
    Don
    If you are willing to share more of your findings and any impact the CDI might have had, please let us know. This might be a great learning opportunity for all.
    Thanks,
    Colleen Stukenberg MSN, RN, CMSRN, CCDS
    815-599-6820
    P Please consider the environment before printing this e-mail
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  • edited May 2016
    I am in Region B and at this time we have not received any letters. We
    did have postings of 16 new complex reviews and 2 new automated reviews
    for a total of 14 automated reviews.
  • edited May 2016
    I'll be happy to try to summarize findings when I am through......mostly not surprising stuff at this point.

    Don
  • edited May 2016
    I would be very interested in your results.

    Thank you,
    Susan Tiffany RN, CDS
    Supervisor
    Clinical Documentation Program
    Robert Packer Hospital & Corning Hospital
    570-882-6094 pager 465
    Fax 570-882-6768
    Tiffany_Susan@guthrie.org
  • edited May 2016
    In the review of the Sepsis charts, did you see many charts with the
    coding of the MS DRG unspecified Sepsis with the principle diagnosis of
    SIRS.
    Debbie
  • edited May 2016
    No, we have not received any yet.

    Michelle Clyne, RN, BS
    Clinical Documentation Improvement Specialist
  • edited May 2016
    I could be wrong, but I thought the code for SIRS can't be the PDx. According to the ICD-9-CM Official Guidelines for Coding and Reporting Effective October 1, 2009:

    "The Coding of SIRS, sepsis and severe sepsis

    The coding of SIRS, sepsis and severe sepsis requires a minimum of 2 codes: a code for the underlying cause (such as infection or trauma) and a code from subcategory 995.9 Systemic inflammatory response syndrome (SIRS).
    (i)
    The code for the underlying cause (such as infection or trauma) must be sequenced before the code from subcategory 995.9 Systemic inflammatory response syndrome (SIRS).

    Codes from subcategory 995.9 can never be assigned as a principal diagnosis. A code should also be assigned for any localized infection, if present."

    To read the complete guideline, go here;

    http://www.cdc.gov/nchs/data/icd9/icdguide09.pdf - Begins on page 16 of 112.

    These guidelines are also published in the front of every ICD-9 Manual.

    This is a confusing subject, for sure. No wonder it's a RAC focus!
  • edited May 2016
    I just received the request below. Please clarify whether it is legitimate. If so, can it be posted without having to register for Cisco services?

    --Juan
  • edited May 2016
    Yes- I sent it encrypted accidentally I have tried sending it again
    w/out the hippa filter



    Adrienne Baker, RN
    Documentation Specialist
    212-5245
    212-9575 (pager)
  • edited May 2016
    Thank you for sharing that information!!

    N. Brunson,RHIA
    Clinical Documentation Specialist'
    Bay Medical Center
  • edited May 2016
    We are in region D with HealthData Insights our RAC. We received our
    first letter last week requesting 3 records for DRG validation (DRG 314
    & DRG 314). It came to the general hospital address, not the PO box we
    specifically set up for RAC. Seems to be the norm for the letters not
    to be addressed correctly.



    Laura Bohls, RN
    Clinical Documentation Specialist
    Prairie Lakes Healthcare Center
  • edited May 2016
    We're guessing due to only 1 MCC/CC. One of which is ESRD on dialysis, so they can't really argue with us there. We're a small rural facility (82 beds), so that's probably why we only had 3 records requested where others have had more requested.
  • edited May 2016
    Thanks for sharing this info.

    Gina Spatafore, RN
    Clinical Documentation Integrity Specialist
    Waterbury Hospital
    203 573 7647
  • edited May 2016
    We are in Region B and received our first RAC letter last Monday as well. The letter was not sent to our assigned post office box, but to the general hospital address. They requested 10 charts. 1 for Gastroenteritis w/MCC, 1 for CHF, 1 for Renal Failure, 5 for Septicemia w/ and w/o MCC, and 2 for Extensive OR procedure unrelated to principal dx. Our RACs team feels 50% of charts are appealable. The other 50% are for various reasons and not single source failure. Often times we do not have a discharge summary when charts are coded. I believe that we are going to find this issue as a challenge.
  • edited May 2016
    Has anyone heard from region A? We have yet to receive any complex review
    charts and would almost like to get started! The suspense and continual
    preparation are almost killing me! I have many concerns as to what RAC
    will find ...............

    Thank you,
    Susan Tiffany RN, CDS
    Supervisor
    Clinical Documentation Program
  • edited May 2016
    Thank you for this information. We are still awaiting our first record requests.
    Lisa Taylor, RN
    Clinical Documentation Specialist
    Wooster Community Hospital
    Wooster, OH
  • edited May 2016
    We are Region A and waiting on pins and needles also.

    Karen Frosch, CCS, CCDS
    Christiana Care - Performance Improvement
    Clinical Documentation Improvement Manager
    302-733-4642 (office)
    302-383-7177 (cell)
    "If you have built castles in the air, your work need not be lost;
    that is where they should be. Now put the foundations under them"
    - Henry David Thoreau
  • edited May 2016
    Are you or someone from your dept, a member of your facilities RAC team?

    Thank you,
    Susan Tiffany RN, CDS
    Supervisor
    Clinical Documentation Program
    Robert Packer Hospital & Corning Hospital
    570-882-6094 pager 465
    Fax 570-882-6768
    Tiffany_Susan@guthrie.org
  • edited May 2016
    Yes....I'm am the RAC Liaison, the CDI Specialist and the ROI Specialist
    both are committee members.



    Theresa Hall, RHIT, ACPAR
    Director of HIM/HIPAA Privacy Officer
    East Georgia Regional Medical Center
    P. O. Box 1048
    1499 Fair Road
    Statesboro, GA 30458
    T: 912-486-1761
    F: 912-871-2388
    theresa.hall@hma.com
  • DCS has not requested any records for complex reviews to date. Please
    don't be so anxious!!! Appealing is a very long process!!!
  • edited May 2016
    That is the same here. Physicians have 30 days to complete their
    medical record (discharge summaries included). We cannot hold claims
    for 30 days or sometimes longer. We send a sample of our cases for
    pre-bill coding audit and our auditors never require a discharge
    summary.



    Theresa Hall, RHIT, ACPAR
    Director of HIM/HIPAA Privacy Officer
    East Georgia Regional Medical Center
    P. O. Box 1048
    1499 Fair Road
    Statesboro, GA 30458
    T: 912-486-1761
    F: 912-871-2388
    theresa.hall@hma.com
  • edited May 2016
    We received a request today. They are asking for 75 records from 2005
    through 2007.

    Theresa Hall, RHIT, ACPAR
    Director of HIM/HIPAA Privacy Officer
    East Georgia Regional Medical Center
    P. O. Box 1048
    1499 Fair Road
    Statesboro, GA 30458
    T: 912-486-1761
    F: 912-871-2388
    theresa.hall@hma.com
  • edited May 2016
    Exactly!!
    My understanding is RAC is limited to 1 Oct 2007 forward discharge dates!

    Don
  • edited May 2016
    Our experience (800+ bed tertiary care in Region C):
    87 records requested (and now submitted), scattered dates.
    Groupings:
    % felt OK (most groupings to small to estimate with confidence)
    Major Chest Procedures 6 70%
    Other Resp OR 4 50%
    GI Surgical 5 80%
    GI Medical 9 30%
    Sepsis 29 50%
    Procedures Unrelated to PDX 33 80%

    ALL of the sepsis were either 1 or 2 LOS, with MCC, no expired patients.

    A common element among many of the other was a single cc -- an area that review showed some vulnerability.

    The sepsis cases -- also some vulnerability -- mix of a few that simply were not clinically supported; documentation was not carried through the stay (HP, first PN, not second PN or DCS); other forms of poor documentation support (hind sight is 20/20).

    The "other" drgs were actually pretty good.

    After reviewing the records, feel that 60% were pretty solid, 20% anticipate a denial but feel had adequate grounds for a defense, 20% had poor defense. A few were obvious errors -- no defense at all.

    Issues among coding and documentation are not strictly either or, but the leaning between the 2 areas was 50/50.

    My estimate was a probable loss of 12% of the total DRG payments on all of these 87 cases.

    1 or 2 might actually result in higher reimbursement, 1 had a second cc that was not initially coded (coded cc is at risk) & 1 had an MCC that was not coded (??) -- so will be interesting to see how those specific cases are handled.

    Would love to hear what others find as they screen their records!!!!

    Moving forward, providing better focus for ongoing concurrent reviews, will be developing a final validation pre-bill for all short stay sepsis; some educational emphasis on the other findings.

    Don
  • edited May 2016
    Per CMS, they cannot request records pre Oct 1, 2007!
  • edited May 2016
    Sounds like there needs to be a discussion with someone. I am not sure if that is the person over your RAC region or who but it has been mentioned multiple times it is Oct 2007. I would find the supporting documentation of it and send it to them along with a phone call. How frustrating.

    Colleen Stukenberg MSN, RN, CMSRN, CCDS
    815-599-6820
    P Please consider the environment before printing this e-mail
  • I suggest you use the discussion phase to point this out to your RAC.
  • edited May 2016
    Thank you very much Don for again posting this valuable information.
    You have saved us a great amount of time.

    Ann Giuli RN, MPH
    Core Measures/Documentation
    Case Management Dept.
    Stamford Hospital
    203-276-7338
    203-276-1000 Beeper #718
    agiuli@stamhealth.org
  • edited May 2016
    Not sure how I've saved any time -- everyone really needs to (at least at the start) do their own review of requested charts, see where your personal areas of weakness are and make plans or adjustments as appropriate (and hopefully share summary findings that might be relevant or helpful to others).

    Don
  • edited May 2016
    From our understanding the order must say "full inpatient admission" not regular admit, admit or inpatient. We have had several denials for improper admit order and since we implemented the above statement, the number of denials has significantly decreased
  • edited May 2016
    If any know answer or explanation of these topic would be appreciated.
    thanks,

    MA


    j. Define case-mix index and its relevance to CDI programs.
    k. Determine how a hospital’s individual case-mix index is calculated.
    l. Define when and how the IPPS is updated each year.
    m. Explain the goals and findings of the Recovery Audit Contractor (RAC)
    program.
    n. Recognize potential RAC risks.


    Mohammad K. Ahmed, M.D, CCS
    Clinical Documentation Specialist
    Bronx Lebanon Hospital Center
    Health Information Management
    1650 Grand Concourse
    Bronx, NY 10457
    Phone: 718-518-5119
    Fax: 718-518-5634
    Email: mahmed1@bronxleb.org
  • CMI is the average of ther elative weights of the MS-DRGs in your patient paopulation. As relative weight increases, the CMI increases prportionally. To determin CMI for a hospital for a ma month, add the relative weight of each DRG and diveide by the number of patients. I beleive the IPPS is updated each Oct 1st. RAC imparcts CDI in that if a cc/MCC trends one way or antoher then theymay look at that area as not being doumented correctly. ie.e Inappropriate use of ARF. There are several areas that they monitor depending on the states that your in. It is based on Medicare rules and regulations. They look for errors in coding/billing that impact reimbursement. The CCDS exam guide is a great resource for these questions! Hope this helps.
  • edited May 2016
    Dr Ahmed,

    I am curious, where did this list come from? Looks like it came from
    the CCDS Candidate Handbook?
    http://www.hcpro.com/acdis/certification.cfm

    This information is very typical of the content of the ACDIS CCDS Exam
    Study Guide -- a very good basis for learning a lot about Clinical
    Documentation Improvement -- & is also I believe covered in the ACDIS
    Clinical Documentation Specialist's Handbook.

    Can find them for purchase through the CDI Marketplace link:
    http://www.hcmarketplace.com/T1_CDI/listings-Clinical-Documentation-Improvement.html

    Not sure which of the two I would suggest first -- both sit on my shelf
    and are referenced fairly often. If I had to choose, the Exam Study
    Guide has more core knowledge content, while the Handbook seems to have
    more industry/professional/bigger picture content.

    Don
  • edited May 2016
    you are right! I got this from study guide, but I could not find
    explanation.


    Mohammad K. Ahmed, M.D, CCS
    Clinical Documentation Specialist
    Bronx Lebanon Hospital Center
    Health Information Management
    1650 Grand Concourse
    Bronx, NY 10457
    Phone: 718-518-5119
    Fax: 718-518-5634
    Email: mahmed1@bronxleb.org
  • edited May 2016
    My thought is that the treatment of the ABLA makes it codable. One might argue that the are many expected conditions secondary to a primary diagnosis.
    Good Luck!!!
  • uh oh. This makes me nervous as I often push for this dx.
  • I would argue this decision by the RAC because even thought it may be 'expected' that some patients may develop atelectasis, ileus, or acute blood loss anemia, not ALL pts do experience these.

    However, if/when these conditions are present and meet the UHDDS Definition of a Reportable Condition, these should be coded to accurately reflect the acuity, ROM, complexity of care rendered, etc.

    I interpret the following Coding Clinic as supportive of reporting 285.1 when appropriate. I would challenge the RAC to cite the authority for the decision on the basis of the official guidelines and I would include this referenced in C. Clinic.

    AHA Coding Clinicâ for ICD-9-CM, 2Q 1992, Volume 9, Number 2, Pages 15-16



    Question:

    How do you code anemia which is diagnosed following a surgical procedure?



    Answer:

    It is difficult to respond to a question regarding postoperative anemia, since the answer is dependent on the documentation in the medical record. However, the following scenarios should help in deciding which code(s) to use:



    1. If the physician documents postoperative anemia in the medical record, but does not label the condition as a complication, assign code 285.1, Acute posthemorrhagic anemia.



    2. If the physician documents that a complication arose during or resulting from the procedure, such as an abnormal amount of blood loss, code 998.1, Hemorrhage or hematoma complicating a procedure, would be assigned. Code 285.1 may also be assigned.



    3. If surgery results in an expected amount of blood loss and the physician does not describe the patient as having anemia or a complication of surgery, do not assign a code for the blood loss.



    4. If the physician documents anemia in the medical record sometime after the operative episode, but does not state postoperative or complication, query the physician as to whether the anemia can be further specified. If more specific documentation can be obtained, refer to scenarios one and two above. If the anemia is not further specified, code 285.9, Anemia, unspecified, would be assigned.



    5. One should not use blood transfusions as a definitive variable in determining whether or not to code a postoperative anemia as a complication. If the physician describes the patient as having a complication of surgery which is documented as anemia, the anemia can be coded as a complication regardless of whether or not a transfusion was given.



    In addition, if there is normal blood loss during an operation, and the physician has not described the patient as having anemia or a complication of surgery, the lack of a blood transfusion reinforces that the blood loss should not be coded.



    The above scenarios are strictly based on the documentation in the medical record.
  • edited May 2016
    I write all of the clinical arguments for our RAC appeals. If it were me, I would involve the patient's surgeon and get their input. The patient's surgeon would know best if this were an expected outcome. Keep in mind that RAC findings do not necessarily mean that the RAC is correct. Remember that 77% of RAC denials are overturned!


    Kathy
    Kathy Shumpert, RN, CCDS

    Clinical Documentation Improvement Specialist
    Howard Regional Health System
    Office 765-864-8754
    Cell phone 765-432-3961
    Fax 765-453-8152

    When something can be read without effort, great effort has gone into its writing. ~Enrique Jardiel Poncela
  • I don't think the RAC is correct stating the basis for the denial is that this is 'expected'...the key point is the pt did have ABLA and it qualified for reporting.

    An "Expected" outcome versus "unexpected' a factor when deciding how/when/if to report a condition with an ICD "Complication" Code.



    But, ABLA is not a complication per coding and reporting guidelines - 285.1.

    Paul Evans, RHIA, CCS, CCS-P
    Supervisor, Clinical Documentation Integrity, Quality Department
    California Pacific Medical Center
    2351 Clay #243
    San Francisco, CA 94115
    Cell: 415.637.9002
    Fax: 415.600.1325
    Ofc: 415.600.3739
  • edited May 2016
    Appeal! Appeal!! Appeal!!! :)
  • edited May 2016
    I would make sure your RAC knows that throughout this country diagnoses
    are determined by licensed providers such as MDs and NPs. We code and
    also query for additional clarification based on their diagnoses. When
    they answer and more specifically define the diagnoses it is coded based
    on their clinical judgment. The RAC is not a physician group brought in
    to audit physician medical decision making. The law states that we
    assign codes based on physician documentation. Not on what the RAC
    decides the diagnoses are. Don't forget the people hired by the RAC are
    coders and CDSs just like us.

    Donna

    Donna Kent, RN, BSN, CCDS
    Manager, Clinical Documentation Integrity Program
    Clinical Quality and Accreditation
    Torrance Memorial Medical Center
    ph.:310 784-6884 fax:310 784-6899
    donna.kent@tmmc.com
  • edited May 2016
    Hi,
    I found the reference to Coding Clinic 2Q, 1992, Volume 9, Number 2, pages 15-16. But there seems to be a more recent clinic?
    Sorry, but my coding software wouldn't let me cut & paste it here, but check out Coding Clinic 1Q 2007, Volume 24, Number 1, Page 19-- which basically states: "when postoperative anemia is documented without specification of acute blood loss, code 285.9, Anemia, unspecified, is the default. Code 285.1, Acute posthemorrhagic anemia, should be assigned, when postoperative anemia is due to acute blood loss. Revisions were made to the Alphabetic Index in 2004, which direct the coder in the following manner:

    Anemia
    postoperative
    due to blood loss 285.1
    other 285.9"

    Hope that helps?
    Becky Mann
    Sutter Solano Medical Center
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