Tip #11 to Avoid Medicaid Recoupment

I realized that it had been a while since I added a “Tip to Avoid Medicaid Recoupment.” So I decided to remedy that. But this one is a little drastic, and hopefully, not too many providers will adhere to this tip. (And, if you have a sense of humor, this is a bit sarcastic).

Tip #11: Do not accept Medicaid clients.

Obviously, you realize that I do NOT actually want health care providers to stop accepting Medicaid to stop.

But, in my line of work, I see A LOT of Tentative Notices of Overpayment and A LOT of Prepayment Reviews, and A LOT of Medicaid contract terminations or rescissions.

I’ve tried to evaluate the reasons cited by the Department of Health and Human Services (DHHS) and its auditing agents that these millions of documents are noncompliant. I’ve come to a preliminary opinion that the problem is not the documentation of the health care providers.  99.8% of the time the providers have rendered the services, provided quality service, and received proper reimbursement. The problem is either (a) the intelligence of the auditors; or (b) the instructions given to the auditors. The Recoupment Audit Companies (RACs), like Carolinas Center for Medical Excellence (CCME), Public Consulting Group (PCG), and HP Enterprises (HP) are on a rampage to audit as many providers as possible, recoupment as much monies as possible, and, I guess, throw a huge Christmas party at the end of the year celebrating the health care providers they have put out of business and the Medicaid recipients with no health care.  But, hey, they will be able to spring for Dom Perignon.

On a serious note, my point of all this is that I would LOVE to say, “Hey, providers, if you do this, then you will not under a recoupment audit.”

But the RACs’ auditing procedures are arbitrary, not founded in policy, and sometimes as unpredictable as New England weather.

So there is no “one thing” that can prevent you from a RAC Medicaid audit.

The audit could be spurred on by a disgruntled employee calling DMA and accusing you of Medicaid fraud without merit.  Maybe CCME has a list of all the health care providers who accept Medicaid and each day 10 employees get to throw darts at the list, which determines which providers get audited. Maybe DMA has the world’s biggest raffle ticket drum.

Maybe instead of “Tips for Avoiding Medicaid Recoupment,” I should start a series of blogs entitled, “Crazy Reason No. 1 That CCME or PCG Found Noncompliance.”

I will think about it.

In the meantime, if you truly want to avoid a Medicaid recoupment, stop accepting Medicaid.

About kemanuel

Medicare and Medicaid Regulatory Compliance Litigator

Posted on March 28, 2013, in CCME, DHHS, Division of Medical Assistance, Harassment, Health Care Providers and Services, Medicaid Audits, Medicaid Recipients, Medicaid Recoupment, North Carolina, PCG, RAC, Termination of Medicaid Contract, Tips to Avoid Medicaid Recoupment and tagged , , , , , , . Bookmark the permalink. Leave a comment.

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