In September the Center for Medicare and Medicaid Services announced that it will extend Recovery Auditor (RAC) review for Evaluation and Management (E&M) services to 15 states. These 15 states where the expansion is occurring are Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia and West Virginia. This expansion of review to E&M coding has become a concern for many doctors to extent that the CEO of the American Medical Association (AMA), James L. Madara, M.D., wrote a letter to CMS requesting that E&M RAC audits should not be implemented.
The argument behind not extending RAC audits to E&M coding is that E&M coding is very subjective from the doctor’s point of view. It is in the doctor’s discretion to code appropriately for an E&M visit and should not be penalized if they spend more time with patients who need a longer, more detailed visit. Apparently, CMS has not budged and the RAC audits on E&M coding has progressed in the above mentioned 15 states. With the implementation of the audits in these states, the rest of the country will follow.