Home Health & Hospice Week

FL, NC can forego RCD submissions, but risk post-pay review.

The Centers for Medicare & Medicaid Services has tacked another quarter onto its RCD phase-in in two states.

“Due to the continuing public health emergency, CMS will be extending the phased-in participation of the Review Choice Demonstration for Home Health Agencies in Florida and North Carolina until 3/31/21,” RCD contractor Palmetto GBA said in a recent post.

Background: Back in August, CMS announced the phase-in when the program was just kicking off in those states. “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.

While the phase-in is still an option, 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 Palmetto’s 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.

Once again, for agencies in Illinois, Ohio, and Texas that 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 .