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CHA has submitted the attached comments to the Office of Medicare Hearings and Appeals (OMHA), responding to its request for information (RFI) on initiatives to address the current backlog of claims pending at the administrative law judge (ALJ) level of appeals. While CHA applauds OMHA’s willingness to begin to address the backlog through a number of pilot programs, the increase in recovery audit contractor (RAC) claim denials will intensify challenges at the ALJ level without fundamental RAC reform. CHA urges OMHA to improve the transparency of data by continuing to release it on a quarterly basis and including additional information, such as the total number of claims, total charges being appealed by the individual Medicare payment system, the most frequent reason for appeals, the number of requests overturned on appeal and the number of cases that moved to the ALJ level. CHA also urges OMHA to improve communication on its established pilots, such as hosting a provider call to educate hospitals on the methodology of its statistical sampling pilot.
