REVENEWS ARCHIVE
MICs – Fully operational in 2010!
The Centers for Medicare & Medicaid Services (CMS) is rolling out the Medicaid Integrity Program (MIP) and plans to be fully operational in all states in 2010. Medicaid Integrity Contractors (MICs) mission is to focus on the Medicaid program just like the Recovery Audit Contractors (RACs) focuses on the Medicare program. Congress developed the MIP as part of the Deficit Reduction Act of 2005 to identify overpayments and ultimately decrease the payment of inappropriate claims made under the $300 billion a year Medicaid program.
MICs will be contracted by CMS to perform four key tasks:
1. Review Medicaid provider actions
2. Audit claims
3. Identify overpayments
4. Educate providers and others on Medicaid integrity issues and quality of care
There are three different types of MICs; Review, Audit, and Education MICs. The Review MICs will analyze data and identify aberrant claims and potential billing issues and pass the leads on to Audit MICs. Audit MICs will conduct the post-payment audits and identify overpayments. Finally, the Education MICs will work with the Review and Audit MICs to educate providers, State Medicaid officials and others about a variety of Medicaid program integrity issues.
The MIC of greatest concern to providers will be the Audit MIC. Any Medicaid provider may be audited, including, but not limited to, fee-for-service providers, institutional and non-institutional, as well as managed care entities. Providers will be chosen for audit based on data analysis by other CMS contractors. They may also be referred by State agencies. CMS will ensure that its audits neither duplicate state audits of the same providers nor interfere with potential law enforcement investigations.
If a provider receives a Notification Letter that it has been selected for audit, it should gather the requested documents as instructed in the letter. CMS contractors have the authority to request and review copies of provider records, interview providers and office personnel, and have access to provider facilities. Requested records must be made available to the Audit MICs within the requested timeframes. Generally, providers will have at least two weeks before the start of an audit to make their initial production of documents to the Audit MICs.
In obtaining documents, Audit MICs will be mindful of state-imposed requirements concerning record production. Moreover, Audit MICs may accommodate reasonable requests for extensions on document production so long as neither the integrity nor the timeliness of the audit is compromised.
The Audit MICs will also contact the provider to schedule an entrance conference. Notification Letters will identify a primary point of contact at the Audit MIC if there are specific questions about the Notification Letter or the audit process.
Once the audit is complete, the Audit MIC will prepare a draft audit report, which will first be shared with the state and thereafter with the provider. The state and the provider each will have an opportunity to review and comment on the draft report’s findings. CMS will consider these comments and prepare a revised draft report. CMS will allow the State to review the revised draft report and make additional comments. Thereafter, CMS will finalize the audit report, specify any identified overpayment, and send the final report to the state. The State will pursue the collection of any overpayment in accordance with state law. Providers have full appeal rights under state law. The Audit MICs will be available to provide support and assistance to the states throughout the state adjudication of the audit.
CMS is committed to providing support and assistance to the States, who are primarily responsible for combating Medicaid fraud waste and abuse, with the implementation of its Medicaid Integrity Program.
For more information, see “November 2009 MIP Fact Sheet” and “Medicaid Integrity Program A to Z” found at the following links:
http://www.cms.hhs.gov/ProviderAudits/Downloads/mipfactsheet.pdf
http://www.cms.hhs.gov/ProviderAudits/Downloads/mipatoz.pdf
Source: CMS