A good place to determine an organization’s billing and coding compliance risks is by looking at Recovery Audit Contractor (RAC) requests and results. It is important for compliance officers to be on a revenue integrity committee that monitors them. Many of these potential billing errors are identified through outside data analysis.

As most of you know, the Centers for Medicare & Medicaid Services (CMS) has retained contractors called RACs to reopen and revise initial determinations or redeterminations of claims within four years from the date of the initial determination or redetermination upon established good cause.