A smarter way to protect your brand RAC Audits: When to Appeal, How to Appeal – A Guide to Success Featuring: Day Egusquiza AR Systems Proprietary and Confidential - © 2010 Compliance 360 – All Rights Reserved Compliance 360 at a Glance Leading GRC Provider for the Healthcare Industry • 750+ Healthcare Facilities using i Cl Claims i A Auditor dit • 150,000+ Active Users • 950,000+ Regulations • 250 000+ 250,000+ Policies • ZERO Software to Install or Maintain 2 Chief Compliance Officer Chief Risk Officer CEO/ Board General Counsel Internal Auditors Executive Dashboard Virtual Evidence Room Room™ • Regulatory Intelligence and • • • • Content Repository P li M Policy Managementt Automated Assessments Incident Management Surveys • Workflow • Projects • Contracts • Reporting • Documents Audit Management Risk Management Compliance Management • • • • • Risk Frameworks and Models Risk Assessments Controls Testing and Monitoring Incident Management Surveys GRC Pl Platform f • Sarbanes-Oxley Management • Risk Assessments • Internal Audit / Self-Assessment • Claims Audit Management • Incident Management • Surveys • Search • Forums • Meetings • Email Integration Content Providers (Laws and Regulations) HIPAA EMTALA HIPAA, EMTALA, STARK STARK, Red Flags Flags, Vendor Compliance, Compliance ABN ABN, etc etc. 3 Compliance 360 Claims Auditor Usage Today RAC Audits CERT Audits 4 MAC Audits PERM Audits MIC Audits Commercial Audits AR Systems, Inc Training Library Presents RAC ATTACK – A Guide to Successful Appeals “To Appeal or not to Appeal” Chapter 2 I t t Instructor: D E Day Egusquiza, i P Pres AR Systems, Inc RAC 2010 5 RAC –The Recovery Audit Contractor: What’s a provider to do? ¾ ¾ ¾ ¾ ¾ ¾ ¾ ¾ Wh Where are we today? t d ? – powerful f l updates d t Walking thru the process - defense /validation audits/moving forward Impact to departments –from letters to recoupment How will the recoupments work – automated vs complex Prevent the denial but know the Provider Options Tracking and trending 5 levels of appeal – decision points Balancing moving forward as well as looking back RAC 2010 6 Roll out & RAC updates This process is dynamic and may change h daily d il RAC 2010 7 GAO finds CMS still sputtering ¾ ¾ ¾ ¾ ¾ Govt accounting office issued a report (March 2010) that indicated “CMS failed to act on RAC findings results in $231 M loss.” CMS did not actually take steps to correct the vulnerabilities the program uncovered. 5 years after the launch of the demo RAC, CMS has yet to implement corrective measures, let alone appt someone to oversee the process. CMS has taken steps to resolve it’s own coordination issues with the permanent RACs, but 60% of the most significant issues uncovered by the RAC have been ignored. GAO recommended: recommended: a) develop criteria to develop adequate measures to reduce future improper payments; b) identify and prevent future Medicare fee for service thru high level direction within CMS and c) assess the effectiveness of the corrective action plan for reducing future improper payments. RAC 2010 8 Patient Protection and Affordable Care A t March Act, M h 23 23, 2010 ¾ ¾ ¾ ¾ ¾ Focusing on curbing fraud, waste and abuse in the Medicare program. Time period for filing Medicare FFS claims in Section 6404 of the PPACA amended the timely filing requirements to reduce the maximum time period for submission of all Medicare FFS claims to one calendar year after the date of service. Under the new law, claims for services furnished on or after Jan 1, 2010 must be filed within 1 calendar year after date of service. In addition, mandates that claims for services furnished before Jan 1, 2010 must be filed no later than Dec 31, 2010. The following rules apply to claims with dates of service prior to Jan 1, 2010: claims with dates of service before Oct 1, 2009 must follow the prepre-PPACA timely filing rules. Claims with dates of service Oct 1-Dec D 31 31, 2009 mustt be b submitted b itt d b by D Dec 31 31, 2010 2010. Impact on denied claims with rebill potential with the RAC and MIC? RAC 2010 9 O’Connor Hospital Medicare Appeal Council Decision ¾ ¾ ¾ ¾ ¾ ¾ ¾ Many issues involving the ability to bill for OBS when an inpt is denied as incorrect setting, BUT the care was medically appropriate. Currently, there is no ability to bill for OBS hrs or other related outpt services such as drug administration as the revenue codes are excluded from the Part A on a Part B rebill rebill.. However, the ALJ hearing the O’Connor case issues a ‘partially favorable decision’ regarding the ability to rebill OBS. The ALJ found that the “observation observation and underlying care was warranted warranted.” CMS referred the case to the 4th level of appeal asserting that the ALJ erred as a matter of law by ordering Medicare payment for the observation and underlying care provided to the beneficiary because those services are not separately billable under Part A.” The Medicare Appeals Council “does not agree that the case contains error of law.” CMS officials ffi i l have h no comment on the h O’Connor O’C d decision, i i b but d do tellll FierceHealthFinance that ‘at this time, CMS does not expect to change the current rebilling requirements.” RAC 2010 10 CMS Claim’s Review Entities Roles of Various Medicare Improper Payment Reviews Timothy Hill, CFO , Dir of Office on Financial Mgt 9-9-08 presentation Entity Type of claims How selected Volume of claims Purpose of review QIO Inpt hospital All claims where hospital submits an adj claim for a higher DRG. Expedited coverage review requested by bene Very small To prevent improper payment thru upcoding. To resolve disputes between bene and hospital CERT All Randomly Small To measure improper payments MAC All Targeted Depends on # of claims with improper payments To prevent future improper payments RAC All Targeted Depends on the # of claims with improper payments To detect and correct past improper payments PSCZPIC All Targeted Depends on the # of potential fraud claims To identify potential fraud OIG All Targeted Depends on the # of potential fraud claims To identify Fraud RAC 2010 11 Audience Polling Question #1 What is the furthest level of appeal you have gone to and what has your success rate been? Understanding the RAC process With D Decision i i P Points i t RAC 2010 13 Summary: Review & Collection Process 1 Automated Review New Automated Review Issue Posted to RAC’s website 2 RAC makes a claim determination The Collection Process 3 Carrier/ FI/MAC issues Remittance Advice (RA) provider to p From Cmdr Casey, RN, CMS N432: Complex Review 6 New Complex Review Issue Posted to RAC’s Website “Adjustment based on a Recovery Audit” Audit 9 8 Provider submits medical records • Provider has 45 + 10 calendar days to p respond • Providers may request an extension • Claim is denied if no response RAC clinician li i i reviews medical records; Day 41 Carrier/FI/ MAC recoups by offset • Recoupment will NOT occur if: 9provider has paid in full; or 9provider filed an appeal BY day 30 makes a claim determination • RAC has 60 calendar days from receipt p of medical record to send the Review Results Letter 5 If no findings STOP RAC 14 2010 14 Walking Thru – Results Letter Letter-complex reviews only ¾ Results letter is sent regardless of a recoupment. No recoupment is also included. included ¾ Results letter do not include a dollar amt. ¾ Demand D d lletter tt ffollows ll shortly h tl th thereafter ft with a $ amt. ¾ Remittance with N432 notifying of pending recoupment also occurs during the same period. RAC 2010 15 Sample DRG Results Letter 2010 RAC 2010 16 Pt specific results RAC 2010 17 Now you have the Demand RAC letter.. ¾ ¾ ¾ ¾ ¾ ¾ ¾ Review results of the initial validation review. Involve physician if necessary to assist in developing an appeal strategy. If no appeal is appropriate, flag the account for recoupment and monitor. Prepare a letter to send to the pt; watch for Medigap recoupment &/or refunds Determine rebilling potential for lesser services. Determine the value of using the informal 11-40 day discussion period. R Request t an Automatic A t ti Offset Off t off amtt to t be b recouped d from f the MAC. RAC 2010 18 Decision Process ¾ Once the results or demand letter has been received,, each provider/facility must make a decision – to appeal or not to appeal. ¾ Approaches: z z z z z Kitchen sink – appeal everything Determine ‘‘appealibility appealibility’’ of the denial If appealing, decide to appeal within 30 days of the demand and incur interest If appealing, appeal within the normal 120 days, with funds recouped at 41 days, with interest from day 30 If appealing, pp g appeal pp within the normal 120 days, y p pay y the demanded amt within 30 days, no interest. RAC 2010 19 Provider Options – RAC overpayment determination (Noridian Medicare Part A contractor, 3 3--10) Which option should I use? Discussion Period Rebuttal A rebuttal should be submitted only on rare occasions of extreme financial hardship. The rebuttal process allows the provider the opportunity to provide a statement and accompanying evidence indicating why the overpayment would cause extreme financial h d hi hardship. A rebuttal is not intended to review supporting medical documentation. A rebuttal should not duplicate the redetermination RAC 2010 process. The discussion period offers the opport nit to opportunity provide additional information to the RAC to indicate why recoupment should be initiated. It also offers the RAC opportunity to explain the rationale for the overpayment decision. Redetermination A redetermination is the first level of appeal A appeal. provider may request a redetermination when they are dissatisfied with the overpayment decision A decision. redetermination must be submitted within 30 days to prevent offset on the 41st day. 20 More on Provider Options Discussion period Rebuttal Redetermination Who do I Contract RAC Contractor/MAC Contractor/MAC Timeframe Day 1-40 Day 1-15 Day 1-120; must be submitted within 120 days of demand letter. To prevent offset on day 41; file within 30 days but interest will accrue (Transmittal 141) Timeframe begins Automated review reviewupon demand letter: Complex-upon results letter Date of demand letter Upon receipt of demand letter Timeframe ends Day 40 (offset begins on day 41) Day 15 Day 120 RAC 2010 21 New Appeal Transmittal ¾ Transmittal ¾ ¾ ¾ ¾ ¾ ¾ ¾ 1762 1762, CR 6377 July 2 2, 2009 www.cms.hhs.gov/transmittals/downloads/R1762CP.pdf Glossary of terms All appeals are on behalf of the beneficiary. “A provider or supplier may represent that beneficiary on the beneficiary’s behalf. No fee. CMS can assign liability to the pt if they ‘should have known’ nonnoncoverage. Uncommon… “When an appellant requests a reconsideration with a QIC (level 2), the contractor (MAC/FI) must prepare and forward the case file to the QIC. “ Letter format for appeals Elements of each level of appeal pp RAC 2010 22 Understanding ‘interest’ ‘interest’ NEW Transmittal 141, 141 CR 6183 6183, 9 9--12 12--08 “Limitation on Recoupment (935) “ ¾ If the facility decides to appeal a RAC determination--understand the process: determination z z z z z If an appeal is filed within 30 days, the MAC/FI will not take back the funds. (Take back is immediate and will occur within 41 days of notice if no appeal.) However, while the facility is going thru the numerous Medicare steps of appeal, interest will accrue on the amount that is being disputed. If the overpayment dispute is overturned at any level of the appeal process process, the interest will be removed. If the overpayment dispute is not overturned, then the interest is left on the account. Th overpaymentt take The t k back b k will ill iinclude l d th the iinterest. t t There is an incentive to only appeal the determinations where there is a good reason to believe it will be overturned. “Punished’ for appealing pp g all. (www.cms.hhs.gov/transmittals/downloads/R141FM.pdf) RAC 2010 23 Transmittal 141, CR 6183 Section 935/Medicare Modernization Act, 2003 “Limitation on Recoupment” ¾ Overpayments that are subject to limitations on recoupment – appeals will suspend the recoupment recoupment. z z z Post-pay denials of claim under Part A and Part B PostMSP duplicate payment Both have demand letters p y recoveries WITH INTEREST if Medicare will resume overpayment the Medicare overpayment decision is upheld in the appeals process. www.cms.hhs.gov/transmittals/downloads/R141FM.pdf www.cms.hhs.gov/transmittals/downloads/R141FM.pdf. g p . MN 6183 is also available at this website. 99-12 12--08 RAC 2010 24 Impact of Transmittal 141 Without filing an appeal With a timely appeal 1) Recoupment in 41 days 1) Timely = 120 days/redetermination Recoupment/offset will occur on the 41st day, but the appeal can still be fil d filed 2) Timely = 30 days/redetermination from demand letter will stop the recoupment from occurring on the 41st day 3) Timely for level 2 = 180 days 4)) Timelyy for level 2 to stop p recoupment = 60 days from level 1/redetermination letter RAC 2010 25 What about that Interest? ¾ ¾ Penalty--If an appeal Penalty is filed to stop the recoupment, interest accrues every 30 days until recoupment. t If overturned, no penalty will be assessed. Average rate 11 11.00% 00% ¾ ¾ RAC 2010 Recoupment occurs but money is returned after additional levels of appeal are completed. Interest is paid to the provider if recoupment is overturned. Each 30 day period period. (CR 6183) 26 Audience Polling Question #2 What other types of medical claims audits dit are you managing i with ith your existing RAC Management System? RAC Appeal Process – Mirrors regular Medicare appeal levels with minor exceptions RAC 2010 28 RAC FAQs Q: Will the Recovery y Audit Contractors (RAC) appeal process mirror the regular Medicare appeal pp p process? A: The Medicare appeals process will remain the same for physicians under Part B and Part A nonnon-inpatient claims. The only difference under Part A is for the inpatient hospital claims under the Prospective Payment S t System (PPS). (PPS) In I the th currentt appeals l process, the th first fi t level appeal will go to the Quality Improvement g ((QIO); ) however, the RAC appeals will g go Organization to the Fiscal Intermediary that processed the claim. RAC 2010 29 Timeline for Appeal Process Type of appeal Provider timeline Determination by Decision within… Timeline within. Redetermination 120 days from initial determination FI, Carrier or MAC 60 days of receipt Reconsideration 180 days from the redetermination d t i ti QIC 60 days of receipt Hearing by the ALJ 60 days from the QIC’s reconsideration;; Balance at least $120 ALJ 90 days of receipt Board of Medicare A Appeals l C Councilil 60 days from the ALJ’ decision ALJ’s d i i Board of appeals 90 days of receipt Judicial Review in US district court 60 days from the Council’s decision; at least $1180 US Court Normal legal/court process RAC 2010 30 RAC 2010 31 RAC 2010 32 RAC 2010 33 When Can Recoupments Occur ¾ Options:: Options ¾ ¾ If no formal (1st level) appeal is filed within 30 days(or payment is made) of the recoupment notice,, the recoupment p will occur on the 41st day. 1st level = 120 days to fil B file. Butt if nott d done iin 30 days, eligible for recoupment. ¾ ¾ RAC 2010 If level 2/reconsideration is upheld, recoupment will occur prior to ALJ decision decision. If a date for appeal is missed, recoupment process begins. Interest will either be charged against or added to the acct – depending.. See table 34 Timeframe for Medicare Recoupment Process after the first demand letter Transmittal 141, CR 6183 Ti f Timeframe M di Medicare Contractor C t t P Provider id Day 1 Date of demand letter (date demand letter mailed) Provider receives notification by first class mail of overpayment determination Day 1-40 Day 41 deadline for discussion request. (w/RAC) No recoupment occurs Provider must submit a statement within 15 days from the date of the demand letter Day 1-40 No recoupment occurs Provider can appeal and potentially limit recoupment from occurring Day 41 Recoupment begins Provider can appeal and potentially stop recoupment. RAC 2010 35 Redetermination Documentation Process Send ALL medical records for Redetermination level of appeal Entire medical record reviewed Medicare Redetermination Notice ((MRN)) Summary of the Facts: - Specific claim information Explanation of the Decision: - Most important element of the MRN - Provides the logic for CMSCMS-FI decision. decision What to Include in your Request for an Independent Appeal: CMS--FI p CMS provides a list of documentation needed to make a decision for next level of Appeal. RAC 2010 36 RAC Appeal Guidelines May y use CMS CMS--20027 ((Redetermination Request Form) or Send letter on provider letterhead Also include ~ RAC determination letter ~ Detail page specific to claim ~ Any additional supporting information Send to FI RAC 2010 37 3 Potential Outcomes with R d t Redeterminations i ti ¾ Full reversal of the overpayment p y decision.(If ( the recoupment had already occurred, verify no other outstanding debt, then repay.) ¾ P ti l reversall = the Partial th debt d bt is i reduced d d below b l the initial stated amt. FI/MAC will recalculate the correct amt. amt Letter will indicate same same. Recoupment of remaining debt may start no earlier than 61 days from the date of the revised overpayment determination. ¾ Full Affirmation of the Overpayment decision. CMS will issue 2nd or 3rd demand letter which will state begin recoupment on 61st day unless QIC notice of reconsideration appeal filed. RAC 2010 38 2007 History of Redeterminations ¾ ¾ ¾ 186 M claims furnished by hospitals, SNF, HH and other providers. 14.5 M were denied FI/MAC did appx 240,000 Part A redeterminations= d i i 1.7% of these denials resulted in an appeal appeal. ¾ ¾ ¾ ¾ RAC 2010 Redeterminations Dispositions: Part A: 45% % unfavorable, 5% partial, 50% favorable Part B: 37% unfavorable, 3% partial, i l 60% favorable. Not all were RAC/Unable to discern. 39 RAC 2010 40 RAC 2010 41 RAC 2010 42 RAC 2010 43 Who are the Original Medicare Qualified Independent Contractors/QIC/Level 2? ¾ Part A East: Maximus Maximus,, Inc ¾ Part A West: Maximus Maximus,, Inc (as of 12 12--08) ¾ Part P t B North: N th Fi Firstt Coast C t Services, S i IInc ¾ Part B South: Q2 Administrators, LLC ¾ DME: Rivertrust Solutions, Inc Source: www.cms.hhs.gov/OrgMedFFSAppeals RAC 2010 44 Next steps for Recoupment Process Timeframe Medicare Contractor Dayy 60 following g revised Date reconsideration notice of overpayment request is stamped in following redetermination Mailroom, or payment received from the revised overpayment notice Provider Provider must p pay y overpayment or must have submitted request for 2nd level of appeal to stop the recoupment Day 61-75 Recoupment could begin Provider appeals or pays on the 61st day Day 76 Recoupment begins or resumes RAC 2010 Provider can still appeal. Recoupment stops on p of appeal. pp date of receipt 45 How to file a Reconsideration Level 2 ¾ Written appeal pp request q sent to QIC within 180 days of receipt of the redetermination (To stop redetermination. recoupment=60 days) ¾ ¾ ¾ ¾ If the form is not used, a written request must contain all the following: ¾ Bene name Bene’s HIC # Specific service & items for which the reconsideration is requested and specific dates of service Name and signature of party Name of the contractor that made the redetermination Clearly state why you disagree with reconsideration determination determination. ¾ Follow instructions on ¾ Medicare Redetermination Notice ¾ ((MRN)) ¾ Use standard form CMSCMS¾ 20033. Form is mailed with the MRN. RAC 2010 46 3 Potential Outcomes with Reconsiderations ¾ ¾ ¾ Full reversal – same as redeterminations Partial reversal – this reduces the overpayment. p y Q QIC issue a revised demand letter or make appropriate payments if due of an underpayment amt. Recoupment will begin on the 30th day from the date of the notice of the revised payment. Affi Affirmation i – recoupment may resume on the h 30th calendar after the date of the notice of the reconsideration. reconsideration RAC 2010 47 2007 Reconsideration History ¾ ¾ ¾ QIC (Qualified Independent Contractors) processed appox 400,000 appeals in 2007 2007. DME is separate. N allll were Not RAC/unable to discern discern. ¾ ¾ ¾ RAC 2010 Reconsideration Dispositions: Part A: 79% % unfavorable, 3% partial, 18% favorable. Part B: 64% unfavorable, f bl 5% % partial, 31% favorable favorable. 48 And then there was ALJ/Administrative Law Judge ¾ ¾ ¾ ¾ Medicare contractors can initiate ((or resume)) recoupment immediately upon receipt of the QIC’s decision or dismissal notice regardless of subsequent appeal to the ALJ (3rd level of appeal) and all further appeals. If the ALJ level process reverses the Medicare overpayment determination, Medicare will refund both principal and interest collected + pay interest on any recouped funds that may kept from ongoing Medicare payments. If other outstanding debts, interest is applied against those first before payment to the provider is made. Can add up same issue items and fill jointly. RAC 2010 49 Contingency Fee Rules ¾ RAC must payback the contingency fee if the claim was overturned at… z z Demonstration RAC Permanent RAC RAC 2010 first level of appeal any level of appeal 50 RAC ATTACK Rollout ¾ ¾ ¾ ¾ ¾ Create tracking and trending tool. Track all requests – look for patterns as to why the request was sent. Track all recoupments with reasons. reasons Implement physician & nursing documentation training; CDM c C changes; a ges; Dept ept head ead ed o on charge c a ge capture/billable services; coding ed, ed, continued inhouse defense auditing. Determine best practices for TNT.. Develop corrective action w/immediate implementation. This is not optional! RAC 2010 51 Tools for Success ¾ ¾ ¾ ¾ ¾ ¾ Look at a tracking tool Continue to learn from other states as the roll out to 2010 is completed. Watch for ongoing education from CMS Look for trends identified from auditing and data mining. Internally audit, train – audit, train some more Explore creation of a RAC SpecialistSpecialist-the most detailed person in the revenue cycle! RAC 2010 52 RAC 2010 53 First Level of Appeal WHAT: WHO: USING: HOW: TIME: Redetermination Carried out by the FI Form CMS 20027 Send request to MAC/FI 120 days from initial decision ~ No minimum amount in controversy RESULTS: Review must be completed in 60 days MAIL TO: pp Attention: Part A Appeals Check with your FI for correct address RAC 2010 54 Second Level of Appeal WHAT: WHO WHO: Reconsideration C i d outt b Carried by th the QIC/ QIC/qualified lifi d indpt i d t contractor USING: Form CMS 20033 HOW: Request sent to QIC TIME: 180 days from the date of Redetermination decision ~ No minimum amount in controversy RESULTS: Review must be completed in 60 days RAC 2010 55 Third Level of Appeal WHO: Administrative Law Judge (ALJ) HOW: File with the entity specified in QIC’s reconsideration notice (HHS OMHA field office) 60 days y from the date of QIC’s TIME: reconsideration notice ~ Amount in controversy must be at least $120 as of January 1, 2006 RESULTS R RESULTS: Review i mustt b be completed l t d iin 90 d days RAC 2010 56 Fourth Level of Appeal WHO: Medicare Appeals Council (Al referred (Also f d tto as D Departmental t t l Appeals Board) HOW: Carried out by an independent agency within DHHS TIME: 60 days from ALJ decision ~ Amount in controversy – carried in from ALJ RESULTS: 90 days to complete review RAC 2010 57 Fourth Level of Appeal Medicare Appeals Council Address: Departmental Appeals Board, MS 6127 330 Independence Avenue, SW Cohen Building, Building Room G 644 Washington, DC 20201 RAC 2010 58 Fifth Level of Appeal WHAT: WHO: TIME: Federal Court Review Carried out by The Federal District Court 60 days from the Medicare Appeals Council decision INCLUDE: ~ Amount in controversy - $1180 (effective 01/01/06)) ~ Date of request RAC 2010 59 Fifth Level of Appeal Federal Court Review Address: Department of Health and Human Services General Counsel General Counsel 200 Independence Avenue, SW Washington, DC 20201 RAC 2010 60 References Revisions to appeals process l – CR 3530 –MM 3530 – CR 3939 CR 3939 –MM MM 3939 3939 – CR 3970 –MM 3970 – CR 4147 –MM 4147 • Requirements – PUB 100‐04, Chapter 29, Sections 310.1 and 310.1 Information on appeals process http://www.empiremedicare.com/PartA/parta_appeals.htm Documentation requirements – MNU 2006 MNU 2006‐01, 01, January 2006 January 2006 RAC 2010 61 References: Appeals pp information Appeals: Administration Law Judge; Departmental Appeals Board; U.S. District Court Review Changes to chapter 29 – Appeals of claims decisions –revised Appeals of RAC decisions – MNU 2006 02 Appeals of ALJ, Departmental Appeals Board, and U.S. District Court Review – CR 4152 Slide Material Culled from: 1) 06/2007 Medicare Appeals Process Provider Outreach & Education 2) CMS 03/07/2006_Appeals_Session_Materials RAC 2010 62 Audience Polling Question #3 Would you like to learn how AR Systems y or Compliance p 360 can help you manage RAC audits? AR Systems’ y Contact Info Day Egusquiza, President AR Systems, Inc Box 2521 Twin Falls, Id 83303 208 423 9036 d l 1@ i d i [email protected] Thanks Th k for f joining j i i us!! RAC 2010 64 Compliance 360 “Cash Cash for Clunkers Clunkers” www compliance360 com/cashforclunkers asp www.compliance360.com/cashforclunkers.asp Compliance 360 Launches “Cash-for-Clunkers” Trade-In Program Healthcare Providers Can Receive Trade-In Credit When Licensing the Compliance 360 Claims Auditor for Managing Medicare and Medicaid Overpayment Recovery Audits 65
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