Part D RAC Data Validation Contractor

In order to ensure the integrity of the Part D Recovery Audit Contractor (RAC) program, CMS has implemented a Data Validation Contractor (DVC) program. Through the DVC, CMS is able to perform an important, independent quality check that:

• Confirms the RAC's improper payment findings
• Measures the RAC's accuracy rate

Specifically, the DVC analyzes random samples of prescription drug events (PDE) identified by the RAC to contain improper payments. Samples that both the RAC and DVC concur on are considered validated. For those RAC findings the DVC disagrees with, the DVC must provide a rejection reason and explanatory comments, including their recovery calculations. The RAC may either accept or reject the DVC's analysis findings. If rejected, the DVC must collaborate with the RAC to attempt resolution. CMS/CPI is the final decision maker to resolve disagreements on improper payment findings between the DVC and the RAC after they exhaust the several processes discussed above.

Further, the DVC must validate the RAC's improper payment findings before the RAC is permitted to actively pursue overpayments from sponsors.

In addition to approving/disapproving improper payment referrals, the DVC also receives and reviews suggested new audit issues from the RAC and provides recommendations to the New Issues Review Board.

CMS has contracted Livanta, LLC to perform the Part D RAC data validation functions under careful guidance established by CMS.