Thomas Hutchinson Quoted in “CMS’s New MA RAC Strategy: Can It Make a Silk Purse Out of This SOW Document?”

AIS Health

Thomas E. Hutchinson, a Strategic Advisor for EBG Advisors, Inc., was quoted by AIS Health, in “CMS’s New MA RAC Strategy: Can It Make a Silk Purse Out of This SOW Document?” Mr. Hutchinson discusses the draft Statement of Work CMS issued in December for the Medicare Advantage Recovery Audit Contractor program.

Following is an excerpt:

The draft SOW does not shed any new light on the extrapolation issue other than saying the “Lead Analytic Contractor” will develop the extrapolation methodology and CMS must approve it. There still is no mention of what will be the FFS adjuster that the agency in February 2012 pledged to develop as a way of taking into account the error rate in FFS when it calculates the errors in MA risk adjustment. CMS does now have an appeals process for RAC audit findings, something not in place when it first discussed extrapolation, but the rules governing appeals still aren’t clear, according to Tom Hutchinson, a strategic adviser at the Epstein, Becker & Green health care law firm and the former head of CMS’s Plan Payment Group.

Hutchinson acknowledges that, as one industry observer suggested, CMS perhaps could get the RAC audit processes started this year if it adds the MA responsibility to an existing RAC FFS contract, but says any significant recoveries — and thus payments to RACs — would be further down the road.