Cash is the lifeblood of a business. Positive cash flows are just as important as profits when it comes to evaluating an organization’s performance. In the healthcare setting, home health agencies (HHAs) rely heavily on regular cash inflows to provide timely patient care delivery with the main source being reimbursements. Year after year, policy changes are rolled out by CMS which affect payment processes and ultimately, Medicare reimbursement amounts.
One such change is the Request for Anticipated Payments (RAP) phase out which was started in 2020. This posed a huge concern for home health agencies as RAP was a major cash contributor given its upfront payment nature. Many HHAs are expected to encounter challenges but CMS is set on the elimination of RAPs and the introduction of a one-time Notice of Admission (NOAs). At times like this, the best thing to do is to arm yourself and your agency with enough information to make the right decisions and preparations. To keep you updated on this HHA policy change, here are some points you should take note of.
Why will RAPs be phased out?
It is important to know why CMS has pushed for this change despite the concerns raised by numerous providers. For the past few years, CMS has observed an increase in fraudulent RAP schemes wherein home health agencies file and receive high value RAPs without submitting the final claims and then closing their businesses before CMS can enforce punitive actions. The 12-month final claim submission window also does not help CMS timely determine if a fraud is committed or not. To mitigate and prevent future fraudulent and abusive activities, CMS made this move, believing that it will lead to a more responsible payment system for home health services.
What has changed in the process in 2021?
In 2021, upfront or prepayment of RAPs are no longer allowed. Submission of the RAP is still required though once you have received and documented the physician’s verbal or written order reflecting the initial visit’s required services, and once the beneficiary has been admitted to home health with the initial visit in the 60-day certification already having been made. Afterwards, HHAs must submit the RAP within 5 calendar days from the start of care or from the “from date” of each succeeding 30-day periods.
What will happen in 2022?
To reduce the administrative burden on HHAs, in 2022, the submission of RAPs will no longer be required and will instead be replaced by a one-time submission of a Notice of Admission (NOA). The NOA will still have to be submitted to your MAC within the 5 calendar days from start of care. Like RAPs, you must have a verbal or written order from the physician that contains the services required for the initial visit with the initial visit conducted at the start of care. For patients who receive home health care in 2021 and will continue to do so in 2022, you should submit an NOA with a one-time, artificial “admission” date corresponding to the “From” date of the first period of continuing care in 2022.
Not complying to the timelines will result in Medicare implementing certain punitive actions such as no LUPA payments from the “from date” until NOA submission date and a reduction of 1/30th of the wage and case-mix adjusted 30-day period payment amount per delayed day. There are of course certain exceptions that can be made especially when the late submission was out of the agency’s control. Examples of which are floods, earthquakes, Medicare system issues, a newly certified agency which has yet to receive its ID or was only notified of its certification after the Medicare certification date, or any other circumstances that CMS determines to be worthy of an exemption.
It is only natural to feel apprehensive about regulatory changes such as the RAP phase – out and the introduction of the Notice of Admission as this will certainly take time to get used to. However, preparation and a good change management approach through your EMR is the key to address this.
In this area, Data Soft Logic (DSL) can help you. With our intelligent software solution for HHAs, Home Health Centre Ultra, we can lessen your administrative burdens and ensure that you have quick access to the documents you need for timely final claims submission. We understand your struggles and we’re here to help. Schedule a demo with us now.
