Home Health & Hospice Week

1 NOA works for all subsequent periods of care — and also could wreck them.

You’ve got about seven months to get the new Notices of Admission for home health payment up and running, or you’ll risk the entire reimbursement for all related billing periods.

Reminder: The current no-pay Requests for Anticipated Payment will go away at the end of this year, and NOAs will replace them on Jan. 1. The Centers for Medicare & Medicaid Services finalized the NOA requirement in its 2020 home health payment final rule issued Oct. 31, 2019 (see HCW by AAPC, Vol. XXVIII, No. 39-40).

Now CMS has updated the Medicare Claims Processing Manual, Chapter 10, with NOA instructions. “Review the revisions and additions to the relevant Manual sections,” CMS urges in accompanying MLN Matters article MM12256.

Home health agencies must submit one NOA using Type of Bill 32A at the beginning of a patient’s stay, CMS explains in the article. Then they must submit a claim for every following 30-day period of care using TOB 329.

Difference: Currently, the TOB 329 processes as an adjustment to the TOB 322 (RAP), CMS notes in the article. Under the NOA procedure, TOB 329 will “represent an original claim, rather than an adjustment, for all claims with From dates on or after January 1, 2022,” CMS explains.

Medicare will require a new NOA only after an agency discharges a patient, the article spells out.

“To submit an NOA, you must have a verbal or written order from the physician that contains the services required for the initial visit,” CMS instructs. And “you must have conducted an initial visit at the start of care.”

As with no-pay RAPs, if you fail to submit an NOA within five calendar days of the start of care, “there will be a non-timely submission reduction in payment amount … equal to a 1/30th reduction to the wage adjusted, 30-day period payment amount for each day from the HH start of care date until the date you submit the NOA,” CMS says.

Also as with no-pay RAPs, HHAs can file for a timeliness exception for reasons including “an event that produces a data filing problem due to a CMS or MAC systems issue that is beyond your control” and “other circumstances that we or your MAC determines to be beyond your control,” the article highlights.

Plus: “Medicare won’t make Low-Utilization Payment Adjustment (LUPA) per-visit payments for visits that occurred on days that fall within the period of care prior to an NOA submission,” CMS adds.

Note: The three-page MM12256 article is at www.cms.gov/files/document/mm12256.pdf and the 64-page manual update transmittal is at www.cms.gov/files/document/r10758CP.pdf.