Home Health & Hospice Week

It’s too risky not to.

Confusion abounds over how no-pay RAPs and LUPAs affect each other, and that confusion is causing home health agencies to lose their entire payments for some patients.

It’s helpful to know how payment for Low Utilization Payment Adjustment billing periods works as of 2021. Requests for anticipated payment “do not have to be submitted if you know in advance that it will be a LUPA,” allows Lynn Labarta, CEO of Imark Billing in Miami. Medicare will pay a LUPA final claim without a RAP.

However: “Agencies should file a RAP for every 30-day period whether they believe that it will be a LUPA or not,” urges Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. “If you think it is going to be a LUPA and you don’t file the RAP, and at the end of the 30 days you have done visits above the LUPA threshold, there will be no payment at all,” Gaboury stresses. Why? “If the claim is not a LUPA, then a RAP is required and you didn’t file one, and now it is 30 days late so the penalty will prevent a payment,” she warns.

It’s extra risky under the Patient-Driven Groupings Model with LUPA thresholds varying by case mix category, adds consultant J’non Griffin with Home Health Solutions in Carbon Hill, Alabama. “With LUPAs fluid based on the HIPPS score, and the potential for orders which could add visits past the LUPA threshold,” you should just submit all RAPs, Griffin advises.

Additional wrinkle: There’s another good reason to always submit RAPs, Labarta adds. “We like things to be consistent when it comes to RAP submission policies within the agency,” she says. “Too many variations can lead to mistakes.”

Bottom line: “With the varying LUPA numbers under PDGM … the safe practice [is] to submit for all claims so you aren’t having to internally track different processes,” agrees Joe Osentoski with Gateway Home Health Coding & Consulting in Michigan.