WASHINGTON – Those familiar with the Centers for Medicare and Medicaid Services' Recovery Audit Contractor program say the RAC audits haven't been as bad as was predicted when the controversial program was launched in late 2009.

That opinion was put forth during the Fifth National Medicare RAC Summit, held March 9-11 in Washington, D.C. – in particular, during a roundtable session that featured experts from all four federal RAC audit regions.

Charles Cataline, senior director of health policy at the Ohio Hospital Association, in Region B, said only a  few issues have been approved so far for RAC audits, but many of them are complex. Audit activity level varies greatly from hospital to hospital, he said. Teaching hospitals "are drowning in activity," while some critical care hospitals have not had any review requests.

The emphasis in Region B is on documentation, Cataline said. "It's never been more true that if it isn't written, it didn't happen," he said. "Documentation is key to winning an appeal."

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Kathy Reep, from Region C and vice president of financial services at the Florida Hospital Association, said "we're just not hearing the thunder" with regard to the ongoing audits.

"Ten percent of our denials are being appealed, and 86 percent are overturned. So we are very successful," she said. In addition, she said, "many of the hospitals who aren't appealing are tending to agree with the RAC findings."

Many healthcare executives were concerned about receiving requests for 500 documents during an audit, but in Region C, Reep said, most of the requests have been for no more than 100 documents at a time. Only one third of Region C hospitals have reported any audit acitivity.

"I think that's very substantial," Reep said.

Tish Hollingsworth, director of reimbursement for the Kansas Hospital Association in Region D, said the number of audit requests has been slow, but activity is picking up.

"It seems the auditors are doing more every 45 days," she said.

Stewart M. Presser, vice president of the Greater New York Hospital Association, said Region A's RAC contractor has indicated it can't handle a request for 500 documents. Some hospitals that have had audits are not hearing back within the required 60 days, he added.

Cataline advised hospitals to take an aggressive approach and start preparing for an appeal when the "additional documentation request" letter arrives. Be ready to demonstrate a clean shop and be aware of documentation issues, he said.

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