Home Health & Hospice Week

Beware possible penalties for late NOAs.

Home health agencies don’t like the idea of implementing a new Notice of Admission policy any more than the idea of cutting Requests for Anticipated Payment altogether, according to their comments on the HH PPS proposed rule.

“Commenters opposed the use of a NOA and the requirement to submit a NOA within 5 days of the home health start of care,” the Centers for Medicare & Medicaid Services acknowledges in the final rule issued Oct. 31. “These commenters referenced some of the operational and processing issues with the hospice Notice of Election and expressed concern that there could be delay in needed care. Other[s] questioned the burden associated with a NOA process.”

The idea of implementing an NOA process is “scary,” says reimbursement expert Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. If CMS imposes a penalty for not submitting NOAs within five days, as it does to hospices with NOEs, “it will be a disaster,” Gaboury predicts.

On the other hand: If CMS does move forward with eliminating RAPs for everyone altogether, a streamlined NOA process could be better than a no-pay RAP, Gaboury predicts. But that would only be the case if Medicare 1) doesn’t penalize agencies for failing to submit an NOA in a short timeframe; and 2) refrains from imposing sequential billing requirements like those in place for hospices.

CMS’s response to commenters’ concerns is to punt the issue to a future rule, although Medicare officials’ minds come across as nearly made up on the matter. “If we do propose elimination of the split percentage approach, we would do so in future rulemaking and would solicit comments at that time about the process that would be established in regards to the submission of a Notice of Admission,” is all CMS says about NOE difficulties and how they would replicate in a new NOA process.