Renewed RAC Activity Reported

AOPA has recently received reports of increased Recovery Audit Contractor (RAC) activity focusing on the provision of ankle foot orthoses, especially in Jurisdiction A and Jurisdiction D. While the existing RAC contractors have been authorized to begin new audits for some time now, pending the competition for and award of the single, national DMEPOS RAC contract, these reports represent the first significant RAC activity focused on O&P providers since the re-authorization took place.

It is important for AOPA members to ensure that the RAC contractors are playing by the rules, especially when it comes to the limits to the number of Additional Documentation Requests (ADRs) that can be made against a single tax identification number.

Current regulations limit the number of ADR requests for suppliers to 10% of all claims submitted for the previous calendar year, divided into eight periods, each period representing 45 days. In addition, for suppliers who bill under specialty codes identifying them as O&P providers (51, 52, 53, 55, 56, or 57) the limit on ADR requests is capped at 10 ADR requests every 45 days, per Tax ID. AOPA is preparing educational resources to help prepare its members for continuing challenges of RAC audits.

In the meantime, if you have received ADRs related to RAC audits, it is imperative that you challenge any ADR requests that exceed the limits discussed above. Questions regarding this issue may be directed to Joe McTernan at or Devon Bernard at