Home Health & Hospice Week

Beware these NOA pitfalls.

Home health agencies have known about Notices of Admission for quite a while, but knowing about and being ready for are two different things — especially with entire care periods’ reimbursement at stake.

Switching from the RAP to the NOA will be a change. “There will be some issues, as always, with change,” predicts consultant Linda Scott with Scott Solutions in Arlington, Virginia.

But “the NOA will be easier due to it having to be filed at the Start of Care only — once you get past the transition ones,” says billing expert Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee.

“The NOE will be a relatively easy change for agencies,” Scott agrees. “Less info is required than with a RAP, and though the time frame is tight, agencies have worked on a time clock in order to not have payments reduced,” she observes.

It won’t take long for HHAs to catch on, based on hospices’ experience with their similar Notices of Election, expects Julianne Haydel with Haydel Consulting Services in Baton Rouge, Louisiana. For hospices, “at first there were some issues, because failure to send [an NOE] by five days means that no payment is rendered until it is sent,” Haydel relates. “Keeping in mind that those first few days of hospice are among the most expensive, it is a mistake that most hospices only made once or twice before they grew consistent with the process,” she says.

However, NOAs do come with some significant risk areas, experts warn.

Risk No. 1 — Late NOAs: The financial penalty is 1/30th of the billing period payment amount per day for late notices, the MACs review in the billing job aid. “When the admission is done early in the week, there is usually not a problem,” Haydel says. “But the weekend is counted as part of the five days,” she warns. “A Wednesday admission submitted to the office late Friday may be overlooked, costing the agency five days’ worth of payment,” she stresses.

Tip: “This can be avoided if the information that the visit has been made and orders are received is communicated to the biller or the person designated to send the NOA,” Haydel advises.

Risk No. 2 — Missing NOAs: If things fall through the cracks and an NOA doesn’t get billed for a billing period (or periods) at all, the HHA is just out the entire payment with no recourse.

Tip: “The person sending the NOA must be up to speed on who is being admitted and when,” Haydel urges.

Risk No. 3 — Claims system glitches: HHAs may want to plan on delays that are out of their control. “What we learned from the implementation of the no-pay RAP earlier this year is that these kinds of major changes are never ‘easy’ for CMS to implement,” cautions M. Aaron Little with BKD in Springfield, Missouri. “I’m recalling numerous challenges that occurred in getting the no-pay RAPs to process correctly,” he says.

The NOA will come with some benefits to outweigh those risks, though, Scott judges.

“Every agency has found they have admitted patients in an active hospice election, in an open episode with another HHA, or even enrolled in a Medicare advantage plan with a limited network and requiring prior authorizations,” she tells AAPC. “All of these can have negative financial impact in creating potential for non-reimbursable care.” The new NOA process can help HHAs avoid all of those scenarios by requiring what amounts to “registration” of patients, she expects.

Stay On Top Of Medical Records Changes

Implementation of NOAs is still less than four months away, but HHAs should start their prep work immediately. “Agencies should begin now,” Gaboury recommends.

Step one is “questioning EMR vendors to ensure that they are going to be ready,” Gaboury tells AAPC.

“It’s really important that agencies start now trying to learn how their EMR is planning to support the NOA implemen­tation,” ranging from learning the new submission processes to “how the NOA will impact revenue recognition,” Little stresses. “EMR vendors have had over 20 years now of tying revenue recognition for each episode/payment period to the RAP/no-pay RAP billing transaction. Now that there is only to be a NOA for each admission, rather than each payment period, the question is what will the EMR vendor use to know how/when to begin the revenue recognition process for each payment period and how is that different from what it’s doing today?” Little asks.

Bottom line: “Agencies really need to be listening now for updated EMR information so that they know if there is any preparation they need to be doing now,” Little recommends. “This will vary widely by EMR vendor.”

Step two may be figuring out how to handle the new NOA plus the likely implementation of the Value-Based Purchasing payment model on Jan. 1, as CMS proposed in the 2022 proposed rule for HH payment (see HCW by AAPC, Vol. XXX, No. 24-25).

Agencies have “to always balance new work,” Scott advises. With “value-based payment adjustments [being] a much bigger deal” and sucking up all the resources, NOAs may get shuffled to the back burner, she cautions.

Note: See the Monday Minute with Melinda on NOAs at https://healthcareprovidersolutions.com/implementation-of-the-notice-of-admission.