Home Health & Hospice Week

Fraud & Abuse:

Proposed Rule Cites Abuses In Pushing For RAP Elimination

Will out-and-out fraudsters wreck your cash flow?

If you’re wondering why Medicare wants to mess with a good thing when it comes to Requests for Anticipated Payment, take a look at the two cases of RAP fraud and abuse the Centers for Medicare & Medicare Services lists in its newly proposed PPS rule for 2019:

Case #1: A Michigan home health agency “was identified for submitting home health claims for beneficiaries located in California and Florida,” the rule says. The HHA was submitting RAPs with no final claims and “CMS discovered that the address on record for the HHA was vacant for an extended period of time.” Although the HHA had continued billing and receiving payments for RAP claims, it had not submitted a final claim in 10 months. Ultimately, the HHA submitted more than $50.2 million in RAPs and received more than $37.2 million in RAP payments.

“In addition to the large amount of money paid to the HHA, Medicare beneficiaries were also impacted by the HHA’s billing behavior,” CMS notes. “For example, a Florida beneficiary who needed home health services was unable to receive the care required due to the RAP submission by this Provider.”

Case #2: Another Michigan agency “had not submitted any final claims in more than one year and was no longer billing the Medicare program,” CMS adds. Medicare paid the nearly $5.8 million in RAP payments that had no final claim.

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