The Centers for Medicare & Medicaid Services (CMS) announced a revised timeline for implementation of the permanent Recovery Audit Contractor (RAC) program at a meeting for hospital executives held during the second week of September 2008.

While CMS still intends to begin expanding the permanent program nationwide in 2008, outreach to providers will not begin until October 1, 2008. According to Tim Hill, the CMS Office of Financial Management Director, this means that hospitals located in the first round of states will not receive medical record requests until January 2009, the second round until March 2009, and the third round until at least August 2009.

It is unclear what led to the implementation delay, but lawmakers and providers continue to raise questions about the RAC program. The Heart Rhythm Society expressed concern about RAC determinations for ICD procedures in a face-to-face meeting with CMS officials in April. (See also CMS Releases Evaluation of RAC Demonstration, dated July 17, 2008, for more on this issue.)

Members should begin planning for arrival of the RACs now, as there are a number of activities that physicians and their staff can undertake to prepare for the implementation of the nationwide program.

The Society has also developed a list of conditions (PDF, 70K) that warrant inpatient admission status for ICD procedures to assist members in preparation for the arrival of the permanent RAC Program. The revised implementation dates (PDF, 85K) or each state are posted on CMS’ website for download.