Home Health & Hospice Week

HHAs should catch a break on RAPs timely filed, then canceled.

No home health agency is looking forward to the Centers for Medicare & Medicaid Services getting rid of Request for Anticipated Payment reimbursement next year, but at least they’ll be able to do it without further jeopardizing cash flow under newly issued instructions.

Problem: Under the original no-pay RAP instructions issued by CMS, RAPs would be delayed if a visit in a second or later billing period fell beyond the five-day window to submit the RAP. That’s because HHAs would have to wait for the visit date to report it on the 0023 revenue code of the RAP.

Solution: “The HHA may submit these RAPs with the first day of the period of care as the service date on the 0023 line,” CMS says in an updated transmittal dated Sept. 24. “This will allow for the submission of RAPs for two 30-day periods of care immediately after the start of a 60-day certification period. It will also prevent delaying the submission of the RAP for subsequent periods when the first visit in that period would be beyond the 5-day timeframe for a timely-filed RAP.”

In another change, CMS tells HHAs how to avoid the penalty for filing late in one circumstance. “If the RAP that corresponds to a claim was filed late and the HHA is requesting an exception to the late-filing penalty ... enter information supporting the exception category that applied to the RAP,” CMS says in an update to the July transmittal. “If the RAP that corresponds to a claim was originally received timely but the RAP was canceled and resubmitted to correct an error, enter remarks to indicate this condition, (e.g., ‘Timely RAP, cancel and rebill’). Append modifier KX to the HIPPS code reported on the revenue code 0023 line.”

Providers don’t have forever to take advantage of this exception, though. “HHAs should resubmit corrected RAPs promptly (generally within 2 business days of canceling the original RAP),” CMS instructs in CR 11855 at www.cms.gov/files/document/r10396cp.pdf.