Home Health & Hospice Week

Problem: Reviewers for same cert may disagree.

A clarification from CMS about how the Review Choice Demonstration works won’t provide quite as much streamlining as it first appears.

In an Aug. 21 education call on the Patient-Driven Groupings Model, a Centers for Medicare & Medicaid Services official noted that each 30-day billing period under PDGM will require its own Unique Tracking Number for RCD. That will translate to twice as much RCD work, industry members criticized.

However: “Under the pre-claim review option, HHAs may submit a request with multiple episodes for a beneficiary on one pre-claim review request,” a CMS spokesperson tells Eli, in response to a question about how the process will work.

At first, that sounds like it should be a big time-saver. But not so fast.

The portal for RCD contractor Palmetto GBA “allows providers to submit multiple ‘episodes’ at a time, but they’re still separate ‘requests,’” explains one industry veteran. “So, that means the provider still has to separately attach a plan of care, face-to-face, etc., for each ‘request.’”

While the single submission might save a little processing time, the multiple requests can still cause big problems.

For example: Face-to-face documentation “has to be included with each PCR ‘request,’ even if multiple ‘requests’ are being made with a single ‘submission,’ the source says. “Not only does this create more work for the provider, but it puts PGBA in a position where one reviewer could potentially non-affirm a PCR request for the same FTF documentation that was affirmed for the prior request. And, this has happened.”