Home Health & Hospice Week

Medicare appears to be eliminating RAPs for as many home health agencies as it can as quickly as it can.

Reminder: The Centers for Medicare & Medicaid Services discontinued Requests for Anticipated Payment altogether under the Patient-Driven Groupings Model for new HHAs, over vociferous protest from the industry (see Eli’s HCW, Vol. XXVIII, No. 36).That elimination applied as of January 2020 for agencies enrolling as of January 2019. But then in February 2019, to make sure to stop the flow of RAP money to any new agencies, CMS also announced it would put new HHAs under a period of “enhanced oversight” that included 100 percent RAP suppression. And that suppression lasted through to 2020.

Now CMS has updated a MLN Matters article clarifying that in 2019 “enhanced oversight” RAP suppression applied to “new” providers, which includes providers that newly enroll in the program, providers that submit changes of ownership (CHOWs), and providers that submit changes of information reporting a100 percent ownership change.

But as of 2020, the enhanced oversight RAP suppression won’t apply to newly enrolling agencies, because PDGM already cuts off their RAPs. It will still apply to CHOWs and 100 percent ownership change information circumstances, however, CMS clarifies.

And of course, in 2021 RAP payments go away for all HHAs for good (see Eli’s HCW, Vol. XXVIII, No. 39-40).

The MLN Matters article updated Feb.12 is at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE19005.pdf.