Home Health & Hospice Week

Know Day 0 apart from Day 1.

Home health agencies need to get the details straight on when exactly no-pay Requests for Anticipated Payment are considered late and will penalize payment. And the same rules will apply to Notices of Admission, Medicare says.

The Centers for Medicare & Medicaid Services spells out the counting methodology in the 2021 HH payment final rule:

“For purposes of determining if a ‘no-pay’ RAP is timely-filed, the ‘no-pay’ RAP must be submitted within 5 calendar days after the start of each 30-day period of care. For example, if the start of care for the first 30-day period is January 1, 2021, the ‘no-pay’ RAP would be considered timely-filed if it is submitted on or before January 6, 2021,” CMS explained in the final rule. CMS offered this example:

“1/1/2021 = Day 0 (start of the first 30-day period of care).

1/6/2021 = Day 5 (A ‘no-pay’ RAP submitted on or before this date would be considered ‘timely-filed’.)

1/7/2021 and after = Day 6 and beyond (A ‘no-pay’ RAP submitted on and after this date will trigger the penalty.)

In the event that the ‘no-pay’ RAP is not timely-filed, the penalty is calculated from the first day of that 30- day period (in the example, the penalty calculation would begin with the start of care date of January 1, 2021, counting as the first day of the penalty) until the date of the submission of the ‘no-pay’ RAP.”

Later, CMS clarified that “if an HHA submits their ‘nopay’ RAP one day late (with a submission 6 days after the start of care), the result would be a 20 percent reduction to the 30-day payment amount,” because 6 is 20 percent of 30.