Home Health & Hospice Week

Reimbursement:

NOA Implementation Hits Even More Bumps

U537F glitch is the latest problem hindering NOA processing.

The implementation of Home Health Notices of Admission has been far from smooth over the past month. Now a newly discovered claims processing error is adding another bump.

Background: “NOAs shall be returned to the provider … if the ‘From’ date of the NOA falls within an existing HH admission period unless condition code 47 is present OR the CCN … on the NOA matches the CCN on the admission period,” HHH Medicare Administrative Contractor Palmetto GBA explains in its Claims Payment Issues Log. “In this situation, the NOA will return with RC U537F. When duplicate NOAs (same patient, ‘From’ date, etc.) are submitted, one will be returned as a duplicate with RC U537F. The other will continue to process for approval or edit for other reasons, if applicable.”

The problem: “RC U537F is assigning incorrectly on some NOAs due to the Common Working File (CWF) not correctly recognizing discharges (patient status other than 30 on the last HH period),” Palmetto details in the log. “A system fix to correct this issue is being created, but an implementation date has not been established.”

“CGS is working with CMS to correct the issue,” adds the HHH MAC on its log.

The solution: Until the fix is in place, “providers need to ensure that RC U537F edited correctly on their NOA,” Palmetto advises. “If a provider determines that RC U537F did not edit” correctly, “we will provide additional updates when available. There is no workaround at this time,” the MAC says.

“Further research is needed to determine the appropriate resolution,” CGS says in a message to providers. “At this time, please refrain from contacting our Provider Contact Center (PCC) regarding this issue as it is currently being researched.”

HHH MAC National Government Services notes a correct U537F scenario. “If a claim has returned with the U537I reason code because there is not a processed 32A NOA in the system, the NOA must be submitted. Once it has processed, the returned claim can be resubmitted for processing,” NGS explains in a Jan. 28 post.

“We have been seeing the U537F issue,” confirms billing expert M. Aaron Little with BKD in Springfield, Missouri. “Sometimes it’s been legitimate because two NOAs were billed for the same dates, which happened due to the challenges we’ve experienced with either the EMR vendor or the CMS/ MAC processing issues,” Little tells AAPC.

“Other times there’s no reason that we can identify as to why the error is occurring,” Little says. “In those cases — as the error description states on the CPIL — we have not found a workaround,” he notes.

Do this: HHAs should “be diligent in monitoring these issues so that if/when the time comes and an exception to the timely filing requirements has to be requested, that agencies are prepared to do so,” Little encourages.

In contrast to the U537F problem, Palmetto has corrected another NOA issue and is clearing related notices.

Problem: “An issue with NOAs that were held for the January 2022 System Release occurred with the system adding Condition Code (CC) 15 to the NOA, causing them to Return to Provider,” Palmetto details on its CPIL.

Solution: “Palmetto GBA has completed re-entering the NOAs that were returned to providers for reason code 19960 into processing,” the MAC reported on Jan. 28.

However, the problem isn’t totally resolved. “This issue may have caused NOAs to be considered late, received beyond the 5-day NOA submission requirement,” the MAC cautions. “Providers will need to request a late NOA exception on the corresponding claim if it was late due to this issue. In the remarks for these exception requests, provider shall enter ‘Late due to CC 15 release,’” the MAC instructs.

Plus, “providers should monitor their NOAs for additional edits,” Palmetto adds.

Note: The CPIL for CGS is at https://cgsmedicare.com/hhh/claims/fiss_claims_processing_issues.html and for Palmetto is at  https://palmettogba.com/palmetto/jmhhh.nsf/T/Claims~Claims Payment Issues Log — scroll down to the NOA entries as necessary.

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