Home Health & Hospice Week

Reminder: No NOA means no reimbursement.

One Notice of Admission Medicare claims system change that took effect this month may lighten your billing load a smidge.

Reminder: NOAs for home health agencies took effect in January 2022. “A timely-filed NOA is submitted to and accepted by the A/B Medicare Administrative Contractor (MAC), home health and hospice (HHH), within five calendar days after the start of care/admission date,” HHH MACs Palmetto GBA and CGS says in NOA exception process articles recently reposted to their websites. “Count five calendar days starting the day after the SOC/admission date to determine timely NOA submission,” the MACs instruct.

“In instances where an NOA is not timely-filed, Medicare shall reduce the payment for a period of care, including outlier payment, by the number of days from the home health admission date to the date the NOA is submitted to, and accepted by, the A/B MAC (HHH), divided by 30,” Palmetto and CGS remind agencies.

With significant reimbursement at stake, “most of the initial NOA are issues were ironed out in the first quarter of last year,” Jackie Benson, a biller with HealthCare Management & Billing Services, tells AAPC.

Extensive education for HHAs has helped them avoid NOA problems, relates Lynn Labarta with Imark Billing in Miami, which is now part of SimiTree Healthcare Consulting.

“The few late NOAs” Benson has seen “have happened because of data entry in the EMR [or] not doing the discharge/ readmit correctly,” she reports. That is, “not starting a new admission but adding the readmit under the old admission,” Benson explains.

Then why have the HHH MACs been posting educational articles about NOAs recently?

It could be because of system changes that took effect earlier this month.

Effective Jan. 1 and implemented on Jan. 3, Medicare claims systems made two changes to NOA processes, according to CR 12790 issued last summer:

Change No. 1: Formerly, when an NOA was submitted indicating the beneficiary transferred from another HHA and the NOA “From” date fell within the period of care of the previous HHA, the “End” date of the previous period was truncated to allow the transfer. If the transfer NOA was then cancelled, the system did not restore the original 30-day “End” date on the original period of the previous HHA.

The hassle was that the original HHA then had to cancel and resubmit its NOA. That was “an avoidable administrative burden on that HHA,” the Centers for Medicare & Medicaid Services acknowledges in the CR. Now, “Medicare systems [will] restore the previous period’s End date when a transfer NOA is canceled.”

Change No. 2: MACs “have reported an issue with claims which have been medically reviewed and are later identified for adjustment due to an incorrect period sequence,” CMS explains in the CR. “In processing the adjustment, Medicare ... changes the User Action Code from the code applied by the medical review to ‘Z.’”

That couldn’t stand, because it erased additional medical review coding on the claim, CMS notes. “If the provider is still on review, this will trigger an unnecessary additional record request to the provider,” the CR points out. “If the provider is no longer being reviewed, the claim continues processing without the medical review coding, which impacts medical review reporting.” Now, the system will no longer erase the medical review information from the claim, CMS says.

Or the spate of NOA articles from MACs may be because HHAs have been skipping over the exception process when they have qualifying NOA problems, suggests billing expert M. Aaron Little with FORVIS in Springfield, Missouri.

“Part of the message is reminding agencies that they should not file an appeal if their claim receives a denial or partial denial for a late NOA, but instead first file for the exception,” Little says of the recent articles. “It’s very possible they’ve seen a spike in agencies skipping the exception and going straight for an appeal,” he notes.

If an HHA fails to submit a timely-filed NOA for a qualifying reason, “it may request an exception, which, if approved, waives the consequences of late filing,” Palmetto and