Home Health & Hospice Week

Both will put your reimbursement at risk, however.

Home health agencies are just starting to grapple with the confusing no-pay Request for Anticipated Payment that took effect Jan. 1, but they should already be planning ahead to next year when Notices of Admission will replace no-pay RAPs.

Background: When the Centers for Medicare & Medicaid Services finalized no-pay RAPs for 2021, it also finalized NOAs starting in 2022. “The information needed for submission of the RAP in CY 2021 will mirror the one-time Notice of Admission (NOA) process, also finalized in the CY 2020 HH PPS final rule with comment period, starting in CY 2022,” CMS said in MLN Matters article MM11855 updated last October.

Experts predict a swell of cash flow problems as no-pay RAPs take effect this month. If HHAs fail to submit and the system fails to accept the no-pay RAP within five days of the start of care, CMS will deduct 1/30 of the period’s payment for every day past of the SOC the no-pay RAP is late. The same will happen with NOAs starting next year.

The Good News

Thanks to the learning curve required by the no-pay RAPs in 2021, “I predict we will be in good shape for the Notice of Admission when it arrives in CY 2022,” says

consultant Sherri Parson with consulting firm QIRT, which has been acquired by McBee.

No-pay RAPs “will help get [HHAs] ready for the NOAs,” agrees billing expert M. Aaron Little with BKD in Springfield, Missouri. “But I really think the NOA process will be easier,” Little tells AAPC.

Why? “RAPs have to be billed for every billing period, whereas NOAs are for every admission,” Little explains.

“The NOA will only be one transaction that needs to be submitted to open the HHA period at the beginning of the admission, rather than two RAPs for every episode,” elaborates Lynn Labarta, CEO and founder of Imark Billing in Miami. “The double RAP submission … has more room for error,” Labarta believes.

NOAs will be like Notices of Election for hospices in that way, CMS confirms in the 2021 HH payment final rule published in the Nov. 4, 2020 Federal Register.

“I think this transition year will actually be more challenging than next year when the NOAs become effective,” Little concludes. (For tips on coping with no-pay RAPs, see HCW by AAPC, Vol. XXIX, No. 42).

To make life easier, CMS “could have gone to NOAs this time around,” suggests Lynn Olson, owner of billing company Astrid Medical Services in Corpus Christi, Texas. “I think they didn’t because of the comfort of the term ‘RAP,’” he says.

The Bad News

Tripping up on an NOA may have more dire consequences than RAP missteps.

“If the NOA in 2022 is not submitted timely, it can be even more costly to agencies than the 2021 RAP rule,” Labarta warns. That’s because one NOA can affect reimbursement for multiple billing periods. If the NOA is found to be lacking later, all the corresponding billing periods can be denied.

Note: The 2021 final rule is at https://www.govinfo.gov/content/pkg/FR-2020-11-04/pdf/2020-24146.pdf. The MLN Matters article is at www.cms.gov/files/document/MM11855.pdf.