Home Health & Hospice Week

If you’re just watching and waiting to see whether Medicare eliminates Requests for Anticipated Payment altogether, you’re not doing enough.

Reminder: In its 2019 Home Health Prospective Payment System final rule, the Centers for Medicare & Medicaid Services announced it would no longer pay RAPs for newly enrolled home health agencies under the Patient-Directed Groupings Model (see Eli’s HCW, Vol. XXVII, No. 39-40). Then in a February transmittal this year, CMS said it would not pay RAPs for newly enrolling agencies in 2019 either, while they are under a period of “enhanced oversight” (see Eli’s HCW, vol. XXVIII, No. 8).

Experts predict CMS could eliminate RAPs for all HHAs, not just new ones, as early as 2022.

“This acceleration of the denial of RAP payments and the inclusion of agencies undergoing a [Change in Ownership] should be seen as a significant movement by CMS toward the total elimination of RAP payments,” says consulting firm The Health Group in Morgantown, West Virginia. “All agencies should be preparing for this future action by CMS.” The agency is likely to use the switch to a shorter 30-day episode as justification for the elimination of RAP payments too, the firm says in its electronic newsletter.

Do this: “Agencies should be monitoring the extent of cash flow impact should RAP payments be eliminated,” The Health Group advises. “The potential cash-flow loss will need to be replaced through equity or financing alternatives that may be available to the agency.”