Introduction

The Recovery Audit Contractor program is one of the largest auditing programs initiated by the Medicare program. Instead of developing an extensive bureaucracy and hiring hundreds of auditors, CMS has decided to have outside auditing and consulting firms perform the studies and audits and then pay these firms a percentage of improper payments either recouped or paid. While healthcare providers might argue that paying these firms on a contingency basis provides an improper incentive to find overpayments, real or otherwise, this is the reality we must accept.