CMS is using multiple tools to keep its bounty hunters accountable. Recovery Audit Contractors must use certified coders for all coding determinations, and are required to use registered nurses or therapists "for other types of reviews, and they're also required to have a physician medical director on staff to oversee the review process," indicated CMS's Amy Reese, project officer for Region C RAC (Connolly Healthcare), during a recent RAC Open Door Forum. RACs also must hire RAC Validation Contractors to perform accuracy reviews. "What they're doing is taking a sample of each RAC's claims and making a decision as to whether they agree with the RAC's improper payment determination on the claim," Reese said on the call. "From there they'll determine an accuracy score." CMS will release those scores to the public yearly.