Home Health & Hospice Week

Here’s what may be next for RCD — including maybe even hospice.

Every expert contacted by AAPC agrees that some sort of geographic expansion is almost certainly in the cards for the newly extended Review Choice Demonstration.

“Medicare sees this as a cost saving to the government,” highlights consultant J’non Griffin with SimiTree based in Hamden, Conn. “I think it will expand past the [current] states,” Griffin notes.

“Oklahoma was added just prior to the end of the original demonstration,” which seems like “a clear sign that RCD was going to be extended in some manner,” observes consultant Joe Osentoski with Gateway Home Health Coding & Consulting in Sterling Heights, Mich. RCD took effect in Oklahoma on Dec. 1, 2023.

Bottom line: “I fully expect expansion into other states,” says Mary Carr with the National Association for Home Care & Hospice.

The $64,000 question is, when and where will RCD expand next?

“When” is a complicated issue, depending on a number of factors including how big the expansion will be, whether it will require training of other MACs, etc. Making predictions on “where” is a bit simpler.

Prediction 1: Within Palmetto’s region. CMS doesn’t appear to be using rulemaking to proceed with RCD, so in theory it can expand RCD whenever and wherever it wants. However, expansion will undoubtedly be easier if CMS starts within the region of the MAC that is currently administering the program.

Palmetto covers the six current RCD states plus 10 more: Alabama, Arkansas, Georgia, Indiana, Kentucky, Louisiana, Mississippi, New Mexico, South Carolina, Tennessee.

In the 2023 Comprehensive Error Rate Testing improper payment rate report, home health and hospice providers in five of the six current RCD states topped the error rate list, notes reimbursement expert M. Aaron Little with FORVIS in Springfield, Mo. Those were “followed by Louisiana and Georgia,” Little tells AAPC, which might suggest “Louisiana could be added to the demonstration, eventually,” he predicts.

Or, CMS might decide to roll RCD out to all Palmetto states as a forerunner to a larger national expansion later, perhaps after the next five-year demo period is over, experts suggest.

Either way, HHAs in a Palmetto GBA jurisdiction state are likely to have a “much higher probability of being included,” Osentoski forecasts.

Prediction 2: Outside Palmetto’s region. CMS “might consider expanding RCD to states with high rates of improper payments or where previous demonstrations have shown significant benefits,” predicts Brian Lebanion with BC Healthcare Consulting in Corbin, Ky. “Likely candidates could include states with large populations of Medicare beneficiaries or those with notable variations in home health care utilization,” Lebanion says, which mostly rules out remaining states within Palmetto’s jurisdiction.

California and New York might make good candidates, given that they each have a “significant Medicare population and diverse healthcare landscape,” Lebanion tells AAPC.

Keep in mind that HHH MAC “CGS is under the same parent company as Palmetto,” so its states might be first in line for an expansion, Carr points out.

The problem is that states seen as high-risk — Michigan, California, Massachusetts, and Nevada in Osentoski’s view — are administered by National Government Services, he notes.