CMS Issues Corrections to Claims Processing Policy and 60 Day Calculation Inconsistency

The Centers for Medicare & Medicaid Services (CMS) has issued Change Request (CR) 12657, removing the requirement to submit a Notice of Admission (NOA) before billing for home health denial notices. The CR also revises home health edit criteria to ensure Medicare systems calculate 60-day gaps in service consistently. CMS’ long-standing policy to exclude billings…

CMS Revises Manual Instructions for the NOA and Allowed Practitioners

The Centers for Medicare & Medicaid Services (CMS) has issued Change Request (CR) 12615 that incorporates policies for the implementation of the  Notice of Admission (NOA) and the subsequent elimination of the Request for Anticipated Payment (RAP). The NOA became effective January 1, 2022. The CR also provides corrections and clarifications regarding who may sign…

CMS Revises HHA Claim Instructions

The Centers for Medicare & Medicaid Services (CMS) has issued corrections to Change Request 11855 through Transmittal 10696, dated, March 31,2021. The revisions include instructions that any principle diagnosis may be reported on the request for anticipated payment (RAP) in order to facilitate timely submission. Since these RAPs are not paid, the accurate principal diagnosis…

CMS Open Door Forum Addresses HIT, Home Health CAHPS and Claims Processing Issues

The January 26, 2021 the Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice, and DME (Durable Medical Equipment) Open Door Forum addressed several issues of interest to home health providers. A summary of the issues pertaining to home health are below. (Matters of interest for hospice providers were covered earlier this week…

Remittance Advice Message for No Pay RAP penalty

The Centers for Medicare & Medicaid Services (CMS) has issued another revision to change request 11855 – Penalty for Delayed Request for Anticipated Payment (RAP) Submission – Implementation. The Change Request (CR) revision added remittance advice message information related to the No Pay RAP penalty. Home health agencies (HHAs) should note that Medicare Administrative Contractors…

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 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 to Supress RAP Payments on New Home Health Agencies

The Centers for Medicare & Medicaid Services (CMS) issued a Med learn (MLN) Matters® article, SE 19005 that will place all new home health agencies (HHAs) into a provisional period of enhanced oversight. The provisional period will include a suppression of all Requests for Anticipated Payment (RAP) payments for 30 days to 1 year, effective…