Home Health & Hospice Week

Warning: Unresolved RAP issues can land you in a fraud contractor’s crosshairs.

If you’re not careful with RAPs, you could end up slowing your cash flow significantly.

To avoid negative consequences from Medicare’s new focus on Request for Anticipated Payment monitoring, find out how the HHH Medicare Administrative Contractors determine an agency should be put on RAP suppression.

Step 1: At least monthly, the Centers for Medicare & Medicaid Services now requires MACs to monitor every home health agency’s RAP billing statistics for “misuse,” CMS notes in CR 10789 issued Aug. 17. Among other problems, MACs will scrutinize whether the number of final claims submitted is less than the number of RAPs submitted generally and the number of final claims submitted late resulting in RAPs being “autocancelled.”

Step 2: At an undisclosed threshold (see related story for an educated guess, p. 280), MACs will send HHAs a warning letter that they are at risk of being put on RAP suppression. At an even higher, undisclosed threshold, MACs will put agencies on RAP suppression. MACs will also offer education, CGS notes on its website.

Definition: “RAP suppression means you continue to bill both RAPs and End of Episode claims,” explains billing expert M. Aaron Little with BKD in Springfield, Missouri. “RAPs move to a ‘paid’ status but no cash is released until the EOE is paid. The EOE ends up paying the full episode amount.”

Step 3: Agencies whose RAPs are suppressed must submit a Corrective Action Plan which should include the following, Palmetto says: a statement of the problem or weakness that caused the delay in filing final claims; proposed solutions to the problem; and the person who is responsible for monitoring the CAP.

“The submission of a CAP does not grant the provider rights to have their RAP payments reinstated,” Palmetto cautions on its website. “The purpose of the CAP is to ensure the provider’s acknowledgement that the CMS regulations must be followed and to ensure the provider is implementing processes to improve their billing patterns.”

Plus: This is where RAP misdeeds can get you on reviewers’ radar. “The MAC shall provide the [Unified Program Integrity Contractor] a list of HHAs with pending or accepted CAPs on a regular basis, i.e., at least monthly,” CMS says in the transmittal.

Step 4: After three months, the MAC will reevaulate the agency’s RAP statistics. If its RAP cancel rate is low enough, the MAC will take the agency off RAP suppression. If not, the agency will stay on RAP suppression — typically for another three months, CMS says in its transmittal.

Step 5: When extending the RAP monitoring period, “the MAC shall coordinate with the UPIC to determine if there is an open investigation concerning the HHA and appropriate next steps,” CMS says.

Note: The transmittal is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R817PI.pdf.