New DMEPOS Recovery Audit Contractor

Last month, CMS awarded new contracts for its Recovery Audit Program, which includes a new contractor for orthotic and prosthetic claims.

What You Need to Know

The Recovery Audit Contractor, otherwise known as RAC, is responsible for performing post-payment Medicare audits to identify and correct improper payments. Since October 2016, Performant has been the RAC for Region 5, which focuses on DMEPOS and Home Health/Hospice claims across the entire country. However, on April 28, 2025, CMS awarded this contract to Cotiviti, LLC. While Performant remains under contract with CMS to support the RAC Program from an administrative and appeals perspective for Region 5, Cotiviti will oversee new reviews, which are anticipated to start this summer.

What This Means for You

A new round of RAC audits from Cotiviti will likely begin within the next three months, and they can review any claims that were paid within the last three years. These audits will be based on one of the approved RAC topics, which relate to medical necessity, documentation requirements, and reasonable useful lifetime of orthotic braces, as well as DME unbundling during an inpatient/SNF stay or Hospice/Home Health period. To help prevent an unfavorable decision, respond to all additional documentation request (ADR) letters within the 45-day deadline and include all required documentation to justify coverage and medical necessity of the device. While new audits will come from Cotiviti, you may still receive notifications from Performant based on past and/or ongoing audits. During this transition, it is important to contact the appropriate contractor with any inquiries, which can be determined by checking the RAC's name on the review results letter.

 For more information on RAC audits, visit CMS's website on the Recovery Audit Program.