Home Health & Hospice Week

If you’ve got a high RAP auto-cancel rate, new overpayment procedures related to Requests for Anticipated Payment may cost you.

Old way: Before this month, “if a RAP canceled because no HH Final Bill was submitted, an overpayment would be established, no demand letter was sent initially; the cancellation appeared on the remittance advice, and the overpayment was eligible for an offset, immediately,” explains HHH Medicare Administrative Contractor Palmetto GBA in a new post to its website. “Because no demand letter was issued, interest would not accrue on the overpayment. If the overpayment had an open balance after aging 60 days, the overpayment was aggregated with any similar overpayments, and a demand letter was issued. This would then make the debt eligible for interest accrual.”

New way: When a RAP auto-cancels, “the overpayment will be established and the cancellation will appear on the remittance notice,” Palmetto continues. Effective Oct. 7, “a demand letter will be issued and the overpayment will not be eligible for an offset until the 41st day. In this case, interest will accrue on the overpayment beginning on the 31st day of delinquency. In addition, the overpayment will not be eligible for appeals.”

Do this: “Providers should determine if they anticipate that future claim payments will be sufficient to recoup the negative balance created by the auto-canceled RAP, or if it is more practical to follow the repayment options provided in the demand letter,” advises HHH MAC CGS in a new post on its website.

The operational change is in a Centers for Medicare & Medicaid Services transmittal from last May, CR 10776, at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2019Downloads/R316FM.pdf, the MACs say.