Home Health & Hospice Week

HHAs must continue to submit RAPs, despite receiving no reimbursement for them.

Medicare has laid out some of the details of its new “enhanced oversight” period and accompanying RAP suppression in a recent article, but many details remain vague.

“At this point, all we know is what is in the Centers for Medicare & Medicaid Services piece,” says National Association for Home Care & Hospice President William Dombi. NAHC has pledged to seek further details from CMS.

For now, here’s what home health agencies know about the process:

Who’s affected: “All new HHAs will not receive RAPs as part of their billing process during the period of time they are in the provisional period of enhanced oversight,” the MLN Matters article says. While it’s not specified, multiple experts predict that means HHAs enrolling after the date of the article (Feb. 10 or later). Or it may refer to agencies enrolling in all of 2019, since they are the ones that already are designated to not receive RAPs under the Patient-Driven Groupings Model.

Criteria. CMS says suppression of RAP payments for newly enrolling providers may last from one month to a year (see story, p. 58), but doesn’t say how the length will be determined. “My own specific gut feeling is that they will be long enough to carry into PDGM, where they will not receive RAP payments if they are a new agency after Jan. 1, 2019,” says consultant J’non Griffin, owner of Home Health Solutions in Carbon Hill, Alabama.

If all RAP suppressions aren’t made to run into PDGM, M. Aaron Little with BKD doesn’t expect CMS to make its criteria for determining the length public.

RAP submission. While newly enrolling home health agencies won’t be eligible for RAP payments, they still must submit the claims. “The HHA still needs to submit a RAP for each home health episode in order for the final claim to be processed,” CMS instructs in the MLN Matters article. “New HHAs that are subject to RAP suppression will receive the appropriate, total payments for their services for each particular home health episode after the submission of a final claim.”

Notice. CMS or one of its contractors will notify new HHAs that are being placed in a provisional period of enhanced oversight via mail. The correspondence will include:

• The date on which the provisional period of enhanced oversight will be effective for the HHA and when it will end; and
• Notice that while the HHA is in the provisional period of enhanced oversight, all RAP payments will be suppressed.

Justification. The authority for the “provisional period of enhanced oversight for new providers” comes from the Affordable Care Act, CMS maintains in the article. “The provisional period of enhanced oversight authority can help CMS address fraud, waste, and abuse concerns regarding particular providers and suppliers.”