Home Health & Hospice Week

Warning: Deadline is tight to submit CAP.

If your RAP practices have gotten sloppy, you’d better be prepared to act fast in response to scrutiny.

Why? The HHH Medicare Administrative Contractors have confirmed that they are following Medicare’s directive to scrutinize home health agencies’ Request for Anticipated Payment statistics for aberrancies, including a high rate of auto-cancels due to timing out (see Eli’s HCW, Vol. XXVII, No. 37).

If Palmetto GBA finds RAP problems, it “shall notify the HHA in writing that a [Corrective Action Plan] is required based on non-compliant billing practices; detail the misuse the MAC identified; indicate the anticipated length of the CAP; and advise the HHA regarding whether the HHA is also being placed on RAP suppression.” Then, “the HHA must submit the CAP within 14 calendar days from the date of the MAC’s letter,” Palmetto instructs.

An agency’s CAP must identify the problem causing the RAP misuse and the proposed solution, in detail, Palmetto explains. The CAP also must include “the individual responsible for monitoring the CAP who will coordinate with the MAC.”

MACs must notify an HHA when they have reviewed and accepted the CAP, and will tell the agency the length of time the CAP will be in place, Palmetto continues. “Normally, CAPs will be implemented for a minimum of 30 calendar days, but the MAC may require a longer implementation period based on the specific problems/weaknesses,” the MAC notes on its website.

Final step: “If the HHA is unable to resolve the issues with the CAP, the MAC shall consider additional corrective action, including RAP Suppression and/or referral to the UPIC,” Palmetto notes on its website.