Home Health & Hospice Week

You’d better keep a close eye on your NOAs and take advantage of payment system glitch workarounds if you want to keep your rightful reimbursement.

Recap: “Periods of care that begin on or after January 1, 2022, either for new admissions or patients continuing care in 2022, require the home health agency (HHA) to submit a one-time Notice of Admission (NOA),” HHH Medicare Administrative Contractor Palmetto GBA reviews in an article updated Jan. 4. “Requests for Anticipated Payment (RAPs) are not to be submitted for periods of care (30-day billing periods) that begin on or after January 1, 2022,” the MAC says.

Unfortunately, the transition from no-pay RAPs to NOAs is not going as smoothly as hoped.

“There have been numerous issues we’ve seen with [electronic medical record] vendors,” reports M. Aaron Little with BKD in Springfield, Missouri. And HHH Medicare Administrative Contractors have issued information on at least one NOA processing glitch so far.

“Can you say natural disaster?” Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn., quips to AAPC.

“NOA is somewhat of a mess right now,” acknowledges J’non Griffin with SimiTree Healthcare Consulting.

The situation is similar to the transition from regular to no-pay RAPs last year, Little recalls. “It feels about the same at this stage,” he observes. “I’m sure it will be a bumpy ride the next few weeks,” he adds.

Problem No. 1: HHAs’ EMR systems don’t work properly.

Solution No. 1: “Having learned from last year’s no-pay RAP implementation, we anticipated there would be issues” with EMRs, Little acknowledges. “So it’s just a matter of rooting out the issues and working with the vendors to get resolution,” he says.

Having staff designated to track your NOAs for these problems is essential, Gaboury says in her Monday Minute with Melinda vlog. You must be “making sure that someone within your organization is tracking those so that they are filed timely and received at the Medicare MAC within that five-day window,” Gaboury stresses.

Remember, the “reduction in payment amount would be equal to a 1/30th reduction to the wage-adjusted 30-day period payment amount for each day from the home health start of care date until the date the HHA submitted the NOA,” HHH MACs Palmetto, National Government Services, and CGS say in a joint job aid about the notices.

And that penalty’s not capped at the end of the 30-day billing period, points out Alora Home Health Software in analysis on its website. “For example, if an NOA is not filed until day 45, the penalty is then actually 45 days,” says the Atlanta-based software vendor. “This makes it critically important to file an NOA on time,” it stresses.

Problem No. 2: “NOAs submitted via EMC [Electronic Media Claims] are returning to the provider (RTP) with reason code 32114 in error,” reports HHH MAC CGS in a Jan. 5 email to providers.

The “CMS tool … isn’t working correctly,” Griffin tells AAPC. “It is stripping Zip codes,” she explains.

Solution No. 2: “To prevent any late NOAs, please use the following workaround,” CGS directs:

• Access the NOA in the DDE Claims Correction screen.
• Enter the nine-digit ZIP code.
• F9/resubmit the claim.

“To avoid this edit, you may choose to submit NOAs via DDE (rather than EMC) until a system fix can be implemented,” CGS suggests.

Plus: “If an NOA is late due to this issue, indicate the following in the Remarks field of the final claim: Jan 2022 Issue RE 32114,” CGS instructs. (Reminder: CMS may grant exceptions to the five-day submission deadline for four reasons, and one of them is “an event that produces a data filing problem due to a CMS or MAC systems issue that is beyond your control,” according to CMS’ transmittal on NOAs, CR 12256).

Problem No. 3: “MACs’ Pricers are also off,” Griffin reports. CMS and the MACs had yet to publicly post that glitch at press time.

Solution No. 3: It’s a matter of “being diligent to stay on top of issues as they emerge, and following workaround instructions like what CGS has issued” for newly announced problems going forward, Little advises.

Bottom line: “Diligence is key,” Little stresses. “Agencies cannot afford to miss important details as they are made available from EMR vendors, MACs, and CMS and other payers (MA plans),” he says.

Note: The MAC job aid is at http://www.palmettogba.com/palmetto/ providers.nsf/files/Billing_the_Home_Health_Notice_of_Admission. pdf/$FILE/Billing_the_Home_Health_Notice_of_Admission.pdf..

CR 12256 is at https://www.cms.gov/files/document/r10839CP.pdf.