The Provider's #1 Resource - Medicare RAC Audits & RAC Appeals
Medicare RAC Appeals & Legal Services / Medicare Compliance & Clinical Reviews / Medicare Fraud & Abuse
Contact Us For Immediate Assistance - (303) 586-5003 or support@racaudits.com
100% Unconditional Compliance Guarantee
Castle Rock Medical Group provides the nation's most efficient & effective professional services solution for the evaluation of RAC audit focus areas and the submission of RAC audit appeals.
CRMG's experienced clinical auditors and Medicare compliance professionals team with the industry's leading health law firms and Medicare lawyers to provide a seamless consulting and legal services solution including - CMS clinical and billing case reviews, case review appeals summaries, required CMS documentation and submission of appeals starting with the initial stage of RAC appeals process.
CRMG absolutely and unconditionally guarantees enhanced CMS compliance by our clients. If CRMG provides formal guidance, consulting or legal services relating to CMS payment criteria – and our client adheres to formal CRMG guidance – CRMG will defend the provider at no additional cost throughout the first 4 levels of the CMS appeals process including – Rebuttal, Redetermination, Reconsideration and the Administrative Law Judge hearing.
This Unconditional Compliance Guarantee is offered for clients under professional services contracts for RAC audit medical reviews & assessments, RAC audit appeals and a wide range of similar CRMG compliance services. Please contact us directly for contract terms & conditions at (303) 586-5003. Mr. Ernie Tsoules
To speak directly with one of CRMG's experienced Medicare consultants or Medicare lawyers - or for questions regarding CMS efforts to stop Medicare fraud & abuse, CMS audits, CMS appeals, RAC audit clinical and billing assessments, Medicare RAC audit documentation, Medicare RAC appeals, RAC appeal attorneys or other Medicare compliance services - please contact us at (303) 586-5003 or support@racaudits.com.
RAC Audit Legal Services - 91% RAC Appeals Success
Castle Rock Medical Group (a Jackson Davis HealthCare company) is the nation's undisputed leader in documenting, applying and implementing CMS clinical payment criteria, implementing Medicare clinical compliance initiatives and completing Medicare RAC audit clinical & documentation assessments. In addition, CRMG has established working relationships with the nations leading health law firms and Medicare RAC appeals attorneys. CRMG's recommended RAC appeals attorneys have assisted with over 10,000 Medicare appeals and have won more RAC appeals than any other single health law firm nationwide.
Success in the RAC appeals process no longer centers on traditional & outdated legal arguments of subjective medical necessity. Focusing on individual patient clinical profiles, required supporting documentation and proving adherence to CMS payment criteria for each case is the only way to win RAC audit appeals.
Through December 31, 2009, CRMG professionals assisted providers facing RAC audits and filing RAC appeals in winning 91% of all RAC appeals cases. In conjunction with these cases, CRMG has assisted in a wide range of RAC appeals efforts - CMS Criteria-Based Case Reviews, CMS Criteria-Based Case Summaries, clinical research, expert testimony and a wide range of RAC appeals legal representation activities.
RAC Appeals & Legal Services Profile
CRMG provides the nation's leading solution for the submission of Medicare RAC audit appeals. CRMG's industry-leading clinical and billing professionals work directly with the nation's best health law firms and provide an unmatched consulting and legal services solution.
See the RAC Audit Appeals section for a detailed overview of CRMG's RAC appeals support process:
Step 1 - CMS Criteria-Based Case Review
Step 2 - Prepare RAC Appeals & Criteria-Based Case Summary
Step 3 - Submit Required Documentation for RAC Appeals
Step 4 - Coordinate with Legal Counsel at Reconsideration
Step 5 - Provide Regulatory & Clinical Expert Testimony
For questions regarding Medicare RAC appeals, CMS billing and clinical case reviews, proactive RAC audit medical assessments or recommended RAC appeals lawyers, please contact us directly at (303) 586-5003 or appeals@racaudits.com.
Turning the Page - A 91% Winning RAC Appeals Strategy
With the permanent RAC audit program being initiated nationwide, providers are preparing for RAC audit denials and setting in motion a series of processes to successfully address RAC appeals. Hospitals, inpatient rehab facilities, physicians and a full range of other healthcare providers are quickly and aggressively turning their focus to fighting & winning RAC appeals. Challenging RAC auditor denials, pushing back the RACs, avoiding fraud allegations and holding on to hard earned cash reserves are all foremost objectives.
Based upon our work with both providers in the demonstration states and those now facing the permanent RAC audit program rollout, the 3 most frequently asked questions are (1) how do we stop these denials in the future and move forward without imploding our clinical infrastructure, (2) how do we win current RAC appeals - and not break the bank doing it, and (3) how do we stop this from turning into 'fraud' allegations and ending up on the front page of the local newspaper.
Within the RAC Audit Appeals we address a wide range of additional issues and strategies to consider when initiating the RAC appeals process. Most importantly, however, we simply can't emphasize enough the very real challenges to winning RAC appeals. Here are a handful of things to consider when tackling the appeals process over the next 12 to 18 months:
1) CMS payment criteria will give you the winning hand
Several U.S. courts have held that a provider's adherence to CMS payment criteria trumps all in the evaluation of claim denials. In fact, the courts have held that - when CMS payment criteria exists for a given focus area - CMS MUST use the payment criteria when evaluating claims for payment;
2) Develop CMS criteria-based case summaries for all "winnable" RAC appeals
Nothing speaks louder in the RAC appeals process than providers that painstakingly tie CMS payment criteria to medical records documentation and present an evidence-based argument for payment;
3) Submit all required documentation during the first 2 stages of the RAC appeals process
It is critical that you file all the supporting documentation relating to a given case no later than Stage II - Reconsideration. After this stage, it is extremely difficult to add supporting documentation to a case under appeal. When completing proactive "mock audits" with providers across-the-country, we have found a number of hybrid medical record structures and significant challenges to submitting medical record documentation for review;
4) Focus on winning in the end
Remember, the Medicare Appeals Council is the last administrative step in the RAC appeals process. Although a select group of demonstration providers did have success with challenging RAC denials at earlier appeal levels, several of these decisions were then subsequently overturned by the Appeals Council - in the end, the Council focused on payment criteria.
RAC Appeals Continuing Education
CRMG offers a wide range of RAC audits & RAC appeals continuing education programs. Each free webcast includes presentations by our industry-leading RAC appeals team and extraordinary insight into the RAC appeals process.
December 1, 2009 - 11:00am - Noon EST
The RAC Appeals Process - How the Game Has Changed
This presentation will address issues associated with RAC audits, RAC overpayment determinations and the RAC appeals process. Over 118,000 RAC claim denials have been appealed by providers in California, Florida & New York - CMS has prevailed in 66% of all RAC appeals cases. This discussion will provide an in-depth look at the RAC appeals process and explore a wide range of opportunities for providers to proactively address RAC audit focus areas.
Please send your registration request and contact information to Jill McGinley via e-mail at compliance@racaudits.com. Registrations must be received no later than November 28. You will receive an e-mail confirmation with sign-on information and password prior to December 1.
February 9, 2010 - 11:00am - Noon EST
Managing the Risk of CMS Audits - Medicare & Medicaid (RAC Audits, PSC Audits, ZPIC Audits, MIC Audits & One PI)
This presentation will address the wide range of ongoing CMS audits & fraud initiatives. Congress has allocated an unprecedented level of financial resources to insuring adherence to CMS payment criteria by providers nationwide - RAC audits, PSC audits, ZPIC audits, etc. CRMG represents hospitals, physicians, inpatient rehabilitaition facilities and physical medicine groups facing day-to-day challenges of both responding to audit requests and managing the risk of potential fraud allegations. This is a critical education session for provider executive management and physicians.
Please send your registration request and contact information to Jill McGinley via e-mail at compliance@racaudits.com. Registrations must be received no later than February 6. You will receive an e-mail confirmation with sign-on information and password prior to February 9.
March 23, 2010 - 11:00am - Noon EST
RAC Appeals - Applicability of the Treating Physician Rule & Other Legal Arguments
This presentation will address CMS audits, CMS appeals and the applicability of the "treating physician rule". CMS and a wide range of judicial findings have determined the relative weight to be given to attending physician testimony, CMS payment criteria, independent medical evidence and other issues in pending appeal matters. With Medicare RAC audits, Medicare PSC audits, Medicare ZPIC audits and Medicaid Integrity Contractor audits (MIC audits) rolling out nationwide and over 1 million RAC appeals being widely anticipated, it is critical that providers understand prior Medicare Appeals Council and U.S. court findings relating to these very important issues.
Please send your registration request and contact information to Jill McGinley via e-mail at compliance@racaudits.com. Registrations must be received no later than March 19. You will receive an e-mail confirmation with sign-on information and password prior to March 23.
CMS / Medicare RAC Appeals Resources
Although the RAC appeals process virtually mirrors other Medicare appeals process steps, CMS has added a handful of high-level documents to it's website. Please see the RAC Audit Appeals section for further information and guidance relating to recommended appeals work plan components. The following are CMS RAC appeals documents highlighted on the cms.hhs.gov website:
RAC Appeals - The Medicare Appeals Brochure
RAC Appeals - Appeals Process Diagram
RAC Appeals - Limitation on Recoupment
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Recommended RAC Appeals Law Firms
As hospitals, inpatient rehabilitation facilities & physicians in the RAC audits demonstration states have encountered, the RAC appeals process can be extremely costly and the timeliness of CMS recoupment is a major challenge.
Knowledgeable, independent health law firms and internal legal counsel representatives play vital roles in the completion of proactive RAC medical review assessments & the submission of RAC audit appeals. In addition, CRMG clinical and legal support professionals emphasize a multi-disciplinary approach to addressing CMS appeals and have assisted with providing expert testimony, clarifying regulatory requirements and contributing to extensive research efforts.
Castle Rock Medical Group has researched hundreds of health law firms nationwide and we are recommending only the very best. Our recommended health law firms and attorneys have hundreds of years of experience, they have assisted with over 10,000 Medicare appeals and more RAC appeals than any law firm nationwide. This very select group of attorneys and firms that can bring both a breadth of experience with the Medicare appeals process and a depth of RAC audit appeals knowledge to each client - without the additional cost.
If you are an experienced Medicare attorney with an interest in being included on our FY 2010 list of recommended RAC appeals lawyers, please contact us at (303) 586-5003 and we would be glad to talk with you.
For questions regarding Medicare RAC Appeals, the 2010 RAC Audits & Appeals Guide, medical review assessments or recommended Medicare RAC lawyers and health law firms in your region, please contact us directly at (303) 586-5003 or appeals@racaudits.com.
NATIONAL - RAC Appeals Lawyers
Multi-State Health Systems
Ms. Lisa Thompson
Fulbright & Jaworski
Washington, D.C.
(202) 662-0398
www.fulbright.com
Mr. Paul Kim
Ober|Kaler
Baltimore, Maryland
(410) 347-7344
www.ober.com
RAC AUDITS DEMONSTRATION STATES - RAC Appeals Lawyers
Mr. Jon Cohn (Region D)
Arent Fox, LLP
Los Angeles, California
(213) 443-7515
www.arentfox.com
Mr. Lloyd Bookman / Ms. Jodi Berlin (Region D)
Hooper, Lundy & Bookman
Los Angeles, California
(310) 551-8111
www.health-law.com
Ms. Renee Jordan (Region C)
Bacen & Jordan, P.A.
Ft. Lauderdale, Florida
(954) 961-5544
rjordan@bacenjordan.com
REGION A - RAC Appeals Lawyers
Maine, Massachusetts, New Hampshire, New York, Rhode Island & Vermont
Connecticut, Delaware, District of Columbia, Maryland, New Jersey & Pennsylvania
Tsoules, Sweeney, Martin & Orr LLC
Exton, Pennsylvania
(610) 423-4200
www.tshealthlaw.com
Mr. Tom Boyle
Buchanan, Ingersoll & Rooney PC
Pittsburgh, Pennsylvania
(412) 562-8800
www.bipc.com
Mr. Nathan Brown
Ropes & Gray
Washington, D.C.
(202) 508-4763
www.ropesgray.com
REGION B - RAC Appeals Lawyers
Illinois, Kentucky, Ohio & Wisconsin
Mr. Charles MacKelvie
Miller, Canfield, Paddock and Stone, P.L.C.
Chicago, Illinois
(312) 460-4234
www.millercanfield.com
Mr. Tom Neal
Krieg DeVault, LLP
Carmel, Indiana
(317) 238-6221
www.kriegdevault.com
Mr. Mike Grubbs
Barnes & Thornburg LLP
Indianapolis, Indiana
(317) 231-7224
www.btlaw.com
Mr. Robert Benvenuti
Barnett, Benvenuti & Butler PLLC
Lexington, Kentucky
(859) 226-0312
www.kyhealthlaw.com
Mr. Mike Cronan
Stites & Harbison PLLC
Louisville, Kentucky
(502) 681-0430
www.stites.com
Mr. Ross D'Emanuele
Dorsey & Whitney LLP
Minneapolis, Minnesota
(612) 343-2161
www.dorsey.com
REGION C - RAC Appeals Lawyers
Alabama, Arkansas, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma, Tennessee, Texas, Virgina & West Virginia
Mr. Buzz Cleveland
Crawford & Cleveland, P.C.
Denver, Colorado
(303) 228-1622
www.health-care-lawyer-denver.com
Ms. Emily Towey
Hancock, Daniel, Johnson & Nagle, P.C.
Glen Allen, Virginia
(804) 967-9604
www.hdjn.com
Mr. Greg Piche
Holland & Hart LLP
Denver, Colorado
(303) 295-8014
www.hollandhart.com
Mr. Kevin Peters
Miles & Peters
Denver, Colorado
(303) 892-9900
www.mphealthlaw.com
Mr. Barry Herrin
Smith Moore Leatherwood LLP
Atlanta, Georgia
(404) 962-1027
www.smithmoorelaw.com
Mr. Tom Stukes
Womble Carlyle Sandridge & Rice, PLLC
Greensboro, North Carolina
(336) 574-8065
www.wcsr.com
Ms. Carla Cox
Jackson Walker L.L.P.
Austin, Texas
(512) 236-2040
www.jw.com
REGION D - RAC Appeals Lawyers
Arizona, Montana,
Alaska, California, Hawaii, Idaho, Iowa, Kansas, Missouri, Nebraska, Nevada, Oregon & Washington
Mr. Steve Adams
Husch Blackwell Sanders LLP
Clayton, Missouri
(314) 480-1500
www.huschblackwell.com
Mr. Stewart Kirkpatrick
Crowley, Haughey, Hanson, Toole & Dietrich
Billings, Montana
(406) 252-3441
www.crowleylaw.com
Mr. Jim Fredman
Foster Pepper PLLC
Seattle, Washington
(206) 447-2909
www.foster.com