Home Health & Hospice Week

Beware potential PEP overpayments, thanks to no-pay Request for Anticipated Payment instructions.

Background: “Change Request Number 11855 allowed HHAs to use a new exception that applies when submitting RAPs for all subsequent periods of care in calendar year 2021,” HHH Medicare Administrative Contractor Palmetto GBA explains on its website. “HHAs may submit these RAPs with the first day of the period of care as the service date on the 0023 line to prevent delaying the submission of the RAP for subsequent periods when the first visit in that period would be beyond the five-day timeframe for a timely-filed RAP.”

The problem: “This new exception may cause overpayments with partial episode payments (PEP) claims as revenue code 0023 may not be the first billable service reported on the claim,” Palmetto says. “In short, using the first day of the period of care as the 0023 line service date instead the date of the first billable service may calculate incorrect PEP adjustment amounts.”

The solution: Home health agencies will have to wait a while for resolution. “A fix to this issue will likely occur in 2022,” Palmetto says. Meanwhile, “HHAs may adjust the overpaid PEP claims and change the 0023 line date to match the earliest visit date to correct their payment,” the MAC advises. “The adjusted claim does not need to have the 0023 revenue code line match the RAP, since the RAP would be cancelled by the original claim.”

Watch out: “Do not cancel the RAP in this process,” Palmetto warns.