Home Health & Hospice Week

Artificial dates for cases that span Jan. 1 with new billing periods are at the top of the pitfall list.

If you think you’re prepared for Notices of Admission to hit in the new year, you may want to think again.

Recap: Citing fraud and abuse concerns and the shorter 30-day payment period under the Patient-Driven Groupings Model, the Centers for Medicare & Medicaid Services replaced regular Requests for Anticipated Payment with no-pay RAPs back on Jan. 1, 2021. Now, over the industry’s objections, CMS is implementing Notices of Admission this coming Jan. 1. NOAs aim to get the home health episode on record so that other providers know about it and can act — and bill — accordingly.

“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,” HHH Medicare Adminis­trative Contractor Palmetto GBA emphasizes in a Dec. 10 post to its website. “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).”

The good news about this change is that home health agencies will get to submit just one NOA per stay, instead of one RAP per 30-day billing period. The change is “very helpful,” cheers reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. “This will reduce the number of transactions and the number of opportunities for problems,” Little tells AAPC.

While transitions are always work-intensive, “once per admission is a good thing,” emphasizes Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan.

Any change in billing procedures has the chance for problems, the experts note. “Given what we went through this year with the implementation of the no-pay RAP, I think we would be short sighted to think there won’t be any troubles with the implementation” of NOAs, Little expects.

But “there were for sure some lessons learned by the no-pay RAP implementation, so hopefully there will be fewer issues with the NOA,” Little says.

Consultant Pam Warmack with Clinic Connections in Ruston, Louisiana, has high hopes for the changeover. “Most providers will have little to no trouble with the NOA process,” Warmack predicts. “The no-pay RAP has prepared everyone in my opinion,” she tells AAPC.

The transition is made easier because “it’s not a complicated change to make for a process similar to RAP submission,” Osentoski expects.

One of the hardest parts of the no-pay RAP implementation was the five-calendar-day deadline before the financial penalty kicked in. HHAs are now used to that requirement, the experts note.

That said, there are plenty of potential flash points to watch out for in the process:

• Artificial admission date. “The one-time need for submitting … an artificial admission date on already open patients seems to be the biggest pending challenge,” Osentoski judges. (See box below for how that will work.) Failure to use those dates will mean returned NOAs that will require lightning quick corrections.
• Timeliness. Like no-pay RAPs, a financial hit to the tune of 1/30 of the billing period payment rate per day will accrue if HHAs submit the NOA more than five calendar days from the start of care. There is a “crucial need for timely submissions to avoid the financial penalty of late submissions,” Osentoski cautions.
• Mode variances. “Where I think there could be issues relate to the differences between the fields required on the NOA if it’s submitted directly into DDE/FISS vs. if the NOA is submitted via the 837 HIPAA compliant claim format,” Little relates. “For example, if directly entering the NOA into DDE/FISS, a HIPPS code is not required; whereas, if submitting via 837 file format a HIPPS code is required,” he explains. “These variances in requirements could potentially result in issues for both CMS and providers,” he predicts.
• No appeal. Except in an extremely limited set of circumstances, HHAs will not be able to appeal late NOAs, meaning any financial penalty incurred will be irreversible.

Note: A video on the new NOA is at https://cgsmedicare.com/hhh/education/vid_noa.html.