Recommendations and Clarifications for HHAs on the No-Pay RAP

Beginning January 1, 2021, home health agencies (HHAs) will be required to submit a request for anticipated payment (RAP) that will be paid at 0 percent, prior to each claim. The Centers for Medicare & Medicaid Services (CMS) finalized the No-pay RAP policy in the CY 2020 Home Health Prospective Payment System Rate Update rule.…

CMS Provides Instructions for Submitting No Pay RAP

The Centers for Medicare & Medicaid Services (CMS) released Transmittal 10254/Change Request (CR) 11855 Penalty for Delayed Request for Anticipated Payment (RAP) Submission – Implementation on July 31, 2020. The CR updates Chapters 3 and 10 of the Medicare Claims Processing Manual with instructions to Medicare Administrative Contractors (MACs) and providers for the generation and…

CMS Revises Provisional Period of Enhanced Oversight Program

The Centers for Medicare & Medicaid Services (CMS) has revised their Provisional Period of Enhanced Oversight program to incorporate policies under the Patient Driven Groupings Model (PDGM) for requests for anticipated payments (RAPs). In February, 2019 CMS announced a Provisional Period of Oversight program that places home health agencies (HHAs) that are newly enrolled or…

CMS Issues Manual Updates Related to PDGM

The Centers for Medicare and Medicaid Services (CMS) has issued Change Request (CR) 11527, which includes further updates to the Claims Processing Manual, chapter 10, related to the Patient Driven Grouper Model (PDGM). The CR clarifies that a beneficiary is not required to be discharged form home health services if an inpatient stay spans across…

Medicare Home Health Services Proposed Rule: RAP Phase-Out

Analysis and recommendations for home health agencies By NAHC President William A. Dombi The Centers for Medicare and Medicaid Services (CMS) has proposed that the split payments made to home health agencies under the Request for Anticipated Payment (RAP) process will end in 2021. As an interim step, no “new” HHAs will receive RAPs in…

CMS Releases Additional Instructions for Claims under PDGM

The Centers for Medicare & Medicaid Services (CMS) has released a second set of revisions to Chapter 10 of the Medicare Claims Processing Manual providing instructions to home health agencies for claims submission under PDGM. CMS Transmittal 4294/Change Request (CR) 11272, Home Health (HH) Patient-Driven Groupings Model (PDGM) – Additional Manual Instructions, provides some clarity…