Medicare RAC Audit on MRIs We have heard from many members regarding receipt of demand letters from a Medicare RAC auditor asking for repayment of previous payment for MRI procedures. The RAC Auditor, Health Data Insights, has asked for repayment of previous MRI procedures alleging that there is evidence that the patient had a pacemaker at the time of the MRI and that policy would prevent payment in that situation. Many of the radiology groups that we have talked to have evidence re patient intake form or otherwise that the patient did not in fact have a pacemaker. Initial requests by some groups for the RAC auditor to reconsider the demand based upon additional information have been denied. The CRS contacted the CMS Regional Office in San Francisco several weeks ago to ask that they investigate the issue. Radiologists have protocols in place to not perform an MRI on any patient with a pacemaker and are aware of the Medicare National Coverage Determination policy. There have been recent changes to that policy but the demand letters involve procedures performed last year. Based upon the discussions with CMS we began a direct dialogue with Health Data Insights (HDI) providing examples of what we believed to be erroneous demands for repayment. In many cases the radiology group provided the patient intake form which asked about the presence of a pacemaker and documented the absence of a pacemaker. Some groups also provided evidence of chest films prior to and after the MRI in question that did not show the presence of a pacemaker. As a result of the conversation yesterday with HDI we can tell you the following; · HDI has halted the audit and is not sending any new demand letters for MRIs. They have found that the parameters they used to connect patient claims involving pacemaker related services and a subsequent MRI were not sufficiently accurate. HDI had searched for the presence of certain ICD-9 code diagnoses in the patient history such as V 45.01 cardiac pacemaker. That may be too broad and they are refining their query for patient medical data. · HDI is also revising their query for search on pacemaker claims to ignore CPT codes or ICD-9 codes that relate to temporary pacemaker claims or evidence of subsequent removal. They will not reactivate the audit until those concerns are resolved. · Some demand letters have been retracted based upon additional research. In that case the provider will be notified that the demand has been withdrawn or revoked. Due to the multitude of examples provided by CRS of specific provider demand letters sent, HDI has taken action to revoke the demand and will so notify the provider. It seems that the issue is working toward resolution. Please contact us if you have any specific questions or issues. To preserve your rights, please honor the time requirements in any demand letters. The first step is to ask for a re-determination by HDI. If that is denied then you should appeal directly to Palmetto. | 
