Home Health & Hospice Week

No-pay RAPs have a few more silver linings too.

If you’re looking for some good news about no-pay RAPs, it does exist.

“This process is definite preparation for the Notice of Admission process that will be required in 2022,” says Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee.

“The attention given to speedy admission processing” for no-pay requests for anticipated payment should serve home health agencies well with NOAs, predicts Joe Osentoski with Gateway Home Health Coding & Consulting in Michigan.

Reminder: NOAs will replace no-pay RAPs in January 2022. Although HHAs railed as hard against NOAs as they did against no-pay RAPs, the Centers for Medicare & Medicaid Services likewise finalized the NOA process in 2019.

Like no-pay RAPs, late NOAs will incur a penalty of 1/30 per day after the five-day deadline. Unlike RAPs, Medicare will require NOAs only once per 60-day certification period instead of once per 30-day billing period.

On one hand: NOAs should “be easier since there will not be a second RAP to have to worry about,” predicts Lynn Labarta, CEO of Imark Billing in Miami. And due to simply going through the RAP process, “agencies should be much better prepared for this coming year,” Labarta expects.

In addition to the mechanics of submitting the RAP, the process set up to constantly monitor submissions, system acceptance, and payment should assist with NOA success. “There are a lot of lessons learned this year that reinforce the need for diligence in 2022,” says M. Aaron Little with BKD in Springfield, Missouri.

On the other hand: NOAs present an additional risk on one front, points out J’non Griffin with Home Health Solutions in Carbon Hill, Alabama. “The most you can be penalized with the no-pay RAP is 30 days,” she explains. “With the NOA, there won’t be that 30-day limit. So if you don’t file the RAP until day 45 — you will lose 45 days of revenue,” Griffin warns.

In The No-Pay RAP Storm, Here Are The Rainbows

Quicker, easier NOA ramp-up is one benefit of dealing with no-pay RAPs now. Here are a few more perks:

• Autocancellations. No-pay RAPs “stop the auto-takeback which were a posting, accounting, and cash flow nightmare,” Labarta cheers. “Posting will be cleaner, much more straightforward to handle,” Labarta says. “Our posters are happy about this change,” she reports.
• Faster submission. The OASIS data doesn’t have to be completed before sending the RAP, removing one obstacle to timely filing, Griffin says. And being able to use “a generic HIPPS code and only the primary diagnosis code makes it faster to enter RAP information,” adds Tim Olson with billing company Astrid Medical Services in Corpus Christi, Texas.
• Fraud prevention. While the extent of RAP fraud and abuse in Medicare has been debated, no-pay RAPs should “get bad actors out of defrauding the government for the easy RAP money that was being paid out,” Labarta says.