AAN Urges CMS to Rescind RAC E/M Audits

October 23, 2012


Neurologists may see their E/M coding come under scrutiny if CMS expands audits to all physicians across the entire nation. The AAN, along with several medical societies representing cognitive specialists, expressed its concern and opposition to the Centers for Medicare and Medicaid Services' (CMS) decision to approve Connolly, Inc., the Recovery Auditor (RAC) for region C, to conduct limited RAC audits for evaluation and management (E/M) services in physician offices.

The letter explains that E/M services are not appropriate for RAC review due to the variability and subjective nature of E/M coding. For example, despite detailed Medicare guidelines that specify the documentation required for each level of E/M service, knowledgeable individuals often reach different conclusions regarding the E/M level of service justified by the documentation. We also comment that these audits will add inappropriate burden on already financially strained providers because they will target the population of providers that can least afford the time it takes to appeal the audit or to hire someone who can appeal on their behalf.  Neurologists and other cognitive specialists tend to receive referrals from primary care physicians for patients with complex medical conditions, thereby leading to a greater use of higher level codes.

The AAN is actively monitoring this issue and will provide updates to our membership as soon as they are available. Members should also contact Daneen Grooms, AAN's Manager of Regulatory Affairs, for additional information or to share their experience with a RAC audit.

Connolly, Inc. region C jurisdiction covers: Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, Puerto Rico, South Carolina, Tennessee, Texas, Virgin Islands, Virginia and West Virginia.