Medicaid Recovery Audit Contractor Audits

Page Updated: April 22, 2024

CHA Advocacy Principle: Doctors and hospitals are committed to compliance and stewardship of Medicaid dollars; however, audits are incredibly time consuming, especially when they are driven by financial scavenger hunts, not patient needs. Audits should be warranted, effective, and efficient.

What Has Been Completed:

Origin: The Affordable Care Act requires states to contract with an outside vendor to review provider claims and propose/complete audits to detect and address Medicaid overpayments.  

Background: There has been an uptick in audit activity and concerns that it is occurring without transparency and accountability from HCPF at a time when hospitals and doctors continue to face significant capacity challenges. In 2023, CHA worked with the General Assembly to pass House Bill (HB) 23-1295 to make several changes to reviews and audits of payments to providers by HCPF and associated processes to recover overpayments or reimburse providers for underpayments.

Outstanding Items:

The bill requires the office of the state auditor to conduct a comprehensive audit to review Colorado’s Medicaid RAC audit practices. Additionally, HCPF must hold quarterly provider convening meetings and trainings, create a RAC provider advisory group, and publish audit activity reports. The state auditor has contracted with BerryDunn to perform the audit. The final audited is expected in June 2024.

Resources: 

• • BerryDunn Audit Survey
  • RAC Coalition Whitepaper
  • HCPF Rebilling Update
  • CHA and Colorado Medical Society Letter to HCPF regarding rule enhancement
  • CHA One-Pager on HB 23-1295
  • CHA Issue Brief
  • HCPF RAC Information 
  • HCPF request email: [email protected]

Meetings/Dates of Note:

• • April 25, 2024 – HCPF RAC Provider Advisory Board Meeting – register here
  • May 2, 2024 – HCPF Quarterly Provider Meeting
  • May 15, 2024 – CO Rac 101 Complex Training – register here
  • June 27, 2024 – HCPF RAC Provider Advisory Board Meeting – register here
  • June 2024 – Final Audit Expected
  • Aug. 1, 2024 – HCPF Quarterly Provider Meeting
  • Aug. 22, 2024 – HCPF RAC Provider Advisory Board Meeting – register here
  • Nov. 13, 2024 – HCPF Quarterly Provider Meeting
  • Dec. 12, 2024 – HCPF RAC Provider Advisory Board Meeting – register here

CHA Staff Contact: Megan Axelrod, CHA director of regulatory policy and federal affairs, [email protected]