Home Health & Hospice Week

CMS sticks to Aug. 1 start date.

Home health agencies are still waiting on many of the details they’ll have to comply with under the imminent pre-claim review demonstration for home health services. But Medicare officials did let slip a few new nuggets in a public meeting June 14:

• The Centers for Medicare & Medicaid Services is sticking to its guns on the Aug. 1 start date for the demonstration in Illinois, a CMS official said in the special Open Door Forum on the demo.
• There will be no time limit on when home health agencies must submit the pre-claim review request, as long as they submit it before the final claim. This contradicts one of the newly released questions-and-answers CMS released last week about the program, which indicated there was a 30-day deadline from the patient’s start of care. CMS will correct that Q&A in the future.
• CMS is giving the Medicare Administrative Contractors funding to hire reviewers explicitly for this demonstration, and have been working with MACs on the initiative already.
• Claims “affirmed” under the demo will be marked off limits for “normal” post-payment review by MACs and Recovery Audit Contractors. However, claims would still be subject to review by Zone Program Integrity Contractors, the HHS Office of Inspector General, Government Accountability Office, and Comprehensive Error Rate Testing (CERT) contractor.
• Watch for CMS to release the operational manual for the demo in the next few weeks.
• CMS will hold another special Open Door Forum on the demo on June 28.
• The MAC will not take back the RAP payment when it “non-affirms” your pre-claim request. Instead, the RAP will automatically auto-cancel on the usual timeline.
• You may submit questions about the demo to HHPreClaimDemo@cms.hhs.gov.

Note: See more about the demo, including links to the Q&As, at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Pre-Claim-Review-Initiatives/Overview.html.