During the November 12 RAC Open Door Forum for Part A providers, CMS announced its intent to do the following with the permanent RAC program:

• Minimize hassles for providers. This includes limiting the volume of medical records RACs may request, and allowing RACs to look back three years instead of four. In addition, CMS is requiring RACs accept imaged records on CD/DVD.
• Maximize transparency. Among other steps, CMS has made it mandatory for RACS to have a Web site showing status of every claim by 2010, as well as send out detailed letters to providers reviewing results. The Web sites will also post types of audits as well as vulnerabilities.
• Maximize accuracy. CMS has required RACs to have medical directors and certified coders (i.e., coders with CCF, CCA, CCSP, CPC, CPC-H, or CRNC credentials).

In addition, during the call, CMS recommended providers take certain steps to prepare for the permanent RAC program. Suggested steps include the following:

• Review and understand all documents from the RAC demonstration
• Review all findings by permanent RACs once the program begins
• Review all current OIG reports at www.oig.hhs.gov/reports.asp
• Review the information on the CMS Comprehensive Error Rate Testing (CERT) Web site at www.cms.hhs.gov/cert
• Put in place an internal audit program

CMS also confirmed that the only two types of claims that are not open for review by RACs are HMO Medicare (Part C) and prescription drug (Part D) claims.