Home Health & Hospice Week

Industry Note:

CHOWs Count Too For RAP Suppression

The official word is in: Provisional enhanced oversight does affect home care providers undergoing a CHOW. So indicates a newly revised Medlearn Matters article.

“For the provisional period of enhanced oversight authority, ‘new’ providers includes all initial enrollments, changes of ownership (CHOWs) that fall under 42 C.F.R §489.18, and changes of information reporting a100 percent ownership change,” says a new sentence in the reissued SE19005.

Why it matters: The Centers for Medicare & Medicaid Services began placing all “new” agencies under enhanced oversight after it issued the article back on Feb. 15. In a surprise move, CMS said it would suppress Requests for Anticipated Payments for agencies in that category.

At the time, industry experts expected the RAP suppression to be merely the first step in CMS’s campaign to eliminate RAPs altogether (see Eli’s HCW, Vol. XXVIII, No. 8). Now the 2020 final rule has proven that prediction true (see related story, p. 318).

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