Medicare Program Integrity Manual (Pub. 100-08), Ch. 4 § 4.3.2.3
MAC Complaint Screening
4.3.2.3 – MAC Complaint Screening
(Rev. 13879; Issued: 07-23-26; Effective: 08-24-26; Implementation: 08-24-26)
A. MAC Screening of CCO Referrals
The MAC shall only screen potential fraud, waste, and abuse complaints, inquiries
referred by the CCO with a paid amount of $100 or greater (including the deductible as
payment), or three (3) or more beneficiary complaints or inquiries, regardless of dollar
amount, about the same provider/supplier. Complaints or inquiries that do not meet the
above threshold for screening shall be closed.
Prior to proceeding with the adjustment of a claim as the result of a second-level
screening, the MAC shall check the Recovery Audit Contractor (RAC) Data
Warehouse (RACDW) for suppressions and/or exclusions. If a suppression and/or
exclusion is present, the MAC shall not adjust the claim and the complaint or inquiry
shall be closed. However, if the MAC determines that the complaint or inquiry
indicates potential fraud, and a suppression and/or exclusion is not present, the MAC
shall make a referral to the UPIC, using the referral guidelines established in 4.3.2.4 –
Referrals to the UPIC.
Each complaint or inquiry shall be tracked and retained for one (1) year. Beneficiaries
inquiring about complaints should be advised that they are being tracked and reviewed.
The MAC shall perform a more in-depth review if additional complaints or inquiries
are received. The MAC shall enter all potential fraud, waste, and abuse complaints or
inquiries received from beneficiaries into their internal tracking system. The MAC shall
maintain a log of all potential fraud, waste, and abuse complaints or inquiries received
from the CCO. At a minimum, the log shall include the following information:
•
Beneficiary name;
•
Provider/supplier name;
•
Beneficiary HICN;
•
Nature of the inquiry;
•
Date received from the initial screening staff (i.e. date the initial
screening staff receives the lead from the CCO);
•
If applicable, date RACDW was checked to confirm the absence of a
suppression and/or exclusion.
•
Date referral was sent to the UPIC;
•
Destination of the referral (i.e., name of the UPIC);
•
Documentation that a complaint or inquiry received from the initial
screening staff was not forwarded to the UPIC and an explanation why (e.g.,
inquiry was misrouted or inquiry was a billing error that should not have been
referred to the screening staff); and
•
Date complaint or inquiry was closed.
The MAC staff may call the beneficiary or the provider/supplier, check claims history,
and check provider/supplier correspondence files for educational or warning letters or
contact reports that relate to similar complaints or inquiries, to help determine whether
or not there is a pattern of potential fraud, waste, and abuse. The MAC shall request
and review certain documents, such as itemized billing statements and other pertinent
information, as appropriate, from the provider/supplier. If the MAC is unable to make a
determination on the nature of the complaint or inquiry (e.g., fraud, waste, and abuse,
billing errors) based on the aforementioned contacts and documents, the MAC shall
order medical records and limit the number of medical records ordered to only those
required to make a determination. The MAC shall only perform a billing and document
review on medical records to verify that services were rendered. If fraud, waste, and
abuse are suspected after performing the billing and document review, the medical
records shall be forwarded to the UPIC for review in accordance with the referral
timeframe identified below.
When a complaint meeting the criteria of an IA or potential fraud, waste or abuse is
received, the MAC shall not perform any screening but shall prepare a referral package
within ten (10) business days of when the inquiry or IA was received, except for
instances of potential patient harm, of which a referral package shall be prepared by the
end of the next business day after the inquiry or IA was received, and send it to the
UPIC during the same timeframe using the guidelines established in section 4.3.2.4 –
Referrals to the UPIC. Once the complaint has been referred to the UPIC, the MAC
shall close the complaint in its internal tracking system.
B. Screening of OIG Hotline Referrals
The MAC shall screen every OIG Hotline complaint received from CMS to determine
if the complaint can be closed, resolved, other appropriate action taken by the MAC, or
referred to either another contractor, a State Medicaid Agency, or Marketplace
Integrity. If the MAC determines that a referral shall be made, the MAC shall adhere to
the referral guidelines established below and in 4.3.2.4 – Referrals to the UPIC.
All OIG Hotline complaints sent to the MAC by CMS shall be reviewed,
determinations shall be made, and final action shall be taken within 45 business days
from the date the complaint is received, unless medical records have been requested
and the MAC is pending receipt of the records. The MAC shall use the date contained
in the e-mail from CMS as the start of the 45 business day timeframe.
If, the MAC requests medical records and those records are not received within 45
business days, the MAC shall deny the claim(s) or keep the request open beyond the 45
business day timeframe to allow for receipt of the requested records, whichever is
appropriate.
If fraud is suspected when medical records are not received or the MAC determines
otherwise that the complaint or inquiry indicates potential fraud, waste, and abuse, the
MAC shall forward it to the UPIC for further development within 45 business days of
the date of receipt from CMS or within 30 business days of the date of receipt of
medical records and/or other documentation, whichever is later. If a referral shall be
made, the MAC shall adhere to the referral guidelines established below and in 4.3.2.4
– Referrals to the UPIC.
If the MAC determines that the complaint or inquiry is not a fraud and/or abuse issue,
and if the MAC discovers that the complaint or inquiry has other issues (e.g., MR,
enrollment, claims processing), it shall be referred to the appropriate department and
then closed.
If the MAC receives a complaint from CMS that has been erroneously assigned to the
MAC, the contractor shall transfer the erroneously assigned complaint to the
appropriate MAC within 10 business days from the date it determined that the
complaint was erroneously assigned.
MACs may receive complaints alleging fraud, waste or abuse in the Medicaid program.
Upon receipt, the MAC shall refer the complaints to the appropriate Program Integrity
Unit (PIU) within the State Medicaid Agency (SMA) noted in Exhibit 47.
The MAC shall identify and refer complaints alleging fraud, waste, or abuse in the
Medicare Part C or Part D programs to the MEDIC. This includes complaints that do
not have a credible allegation of fraud.
The MAC shall identify and refer complaints alleging fraud, waste, or abuse involving
the Federal Marketplace and State-Based Exchanges, insurance agents/brokers
marketing Marketplace plans, and Marketplace consumers to the following email
address: marketplaceintegrity@cms.hhs.gov, with a copy to the MAC CORs. The
MAC shall close the complaint in its internal tracking system. These referrals shall be
done in accordance with the timeframes established above.
The MAC shall only be required to close a complaint from the OIG Hotline in its
internal tracking system and will no longer refer complaints that do not allege fraud,
waste, or abuse involving CMS programs to the OIG.
If the MAC receives duplicate complaints, the second duplicate complaint shall be
closed and cross-referenced to the original complaint. Subsequent complaints will be
thoroughly reviewed to ensure that any new information is added to the original
complaint. This will ensure all items in question related to the complaint are addressed.
When the complaint is closed, monetary actions (if involved) shall only be claimed on
the primary complaint.