Home Health & Hospice Week

Industry Notes:

Review Choice Demo Phase-In Period Keeps Rolling Until Jan. 1

CMS continues to hold off on 25% payment reduction.

Home health agencies in Florida and North Carolina now have a bit more breathing room on the Review Choice Demonstration — but only if they want to gamble with future medical review.

Background: Back in August, the Centers for Medicare & Medicaid Services announced a phase-in of RCD in Florida and North Carolina, where the program was just kicking off. “Claims submitted without going through the pre-claim review process will process as normal and will not be subject to a 25 percent payment reduction,” CMS said on its RCD web page. But “claims may be subject to postpayment review in the future through the normal medical review process,” CMS cautioned.

Now CMS says it will keep the phase-in going until Jan. 1 “due to the continuing public health emergency.” However, providers that start or continue to submit pre-claim review requests will benefit. “Claims that go through pre-claim review and are submitted with a valid UTN will be excluded from further medical review,” according to the Oct. 29 post.

Whether holding off during the phase-in pays off will depend in part on how much postpay review Medicare contractors actually conduct down the line.

As for agencies in Illinois, Ohio, and Texas, which already have been under RCD, it appears their option to not submit claims for pre-claim review, but instead go through prepayment review without a 25 percent penalty, remains in effect. That option is available “until further notice,” CMS said back in August, and the agency hasn’t announced any changes.

See the announcement at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demonstration/Review-Choice-Demonstration-for-Home-Health-Services.

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