Home Health & Hospice Week

Beware: Not signing up puts you in postpay review.

So far, the Review Choice Demonstration launch date and option sign-up schedule are about the only brand-new pieces of RCD information issued. However, home health agencies should pay attention to these points as the RCD launch date rushes up:

• HHAs that don’t proactively sign in and choose from the three initial review options by May 16 “will be automatically placed in Choice 2: Postpayment Review,” the Centers for Medicare & Medicaid Services specifies on its newly updated RCD webpage.
• RCD won’t affect your RAPs. “Request for Anticipated Payments (RAPs) are not included in this demonstration,” CMS says in the Operational Guide. “There is no change in the RAP submission or payment process; a RAP should be submitted as usual to the MAC.”

However: “HHAs who choose Choice 1: Pre-Claim Review, are encouraged to submit the RAP prior to submitting a pre-claim review request,” CMS adds. “The auto cancellation of a RAP when the final has not been submitted timely will also not change under the PCR process.”

Remember that all new home health agencies, under the “enhanced oversight” program announced in February, will receive no RAP payments, despite submitting the RAPs (see Eli’s HCW, Vol. XXVIII, No. 8). That includes HHAs going through a Change of Ownership (see story, p. 104).

• RCD contractor Palmetto GBA will review agencies to see if they meet the 90 percent affirmation rate mark in six-month cycles, according to the Operational Guide.
• CMS will give 60 days’ notice before implementing RCD in any of the remaining demo states, a CMS official noted in the April 3 Home Health Open Door Forum.