Home Health & Hospice Week

CMS goes back to the old way.

Medicare is backtracking on new instructions that could have cost home health agencies with high RAP auto-cancel rates.

Old way: Prior to October, when a request for anticipated payment cancelled because the HHA failed to file a final bill within 60 days of the RAP payment, the system would immediately offset the RAP amount — that is, recoup the RAP payment from any new reimbursement issued.

New way: Last month, the HHH Medicare Administrative Contractors notified agencies that a new process would occur, under which providers would receive demand letters for the RAPs and would have to take action regarding the overpayments (see Eli’s HCW, Vol. XXVII, No. 37).

Old way again: Now the Centers for Medicare & Medicaid Services has put the kibosh on that new procedure, and is directing MACs to go back to the old way of immediate offsets. CMS “has made the necessary corrections within our systems to address this error to ensure that these RAP overpayments will be processed automatically for immediate offset,” HHH MAC Palmetto GBA said in an Oct. 28 message to providers. “Therefore, if your HHA has received a [RAP] overpayment demand letter dated between October 7, 2019 to October 25, 2019, we ask that you please disregard that letter and that no further action is required to remit a check payment or initiate a request for immediate offset.”

For MAC CGS, effective Oct. 28, “a change was implemented to revert back to the original RAP recoupment process,” CGS told providers in a message that day. “A demand letter will not be issued. This means that if you do not submit your final claim within 120 days after the start date of the episode or 60 days after the paid date on the RAP, the RAP payment will be recouped on your Remittance Advice.” On Oct. 29, CGS began making immediate offsets for RAP demand letter amounts, it says.