Home Health & Hospice Week

Get your corrective action plan in pronto to clear up cash flow delays.

If you’re one of the 298 home health agencies Palmetto GBA placed on RAP suppression April 18, now is no time to sit around. The HHH Medicare Administrative Contractor is processing the agencies’ corrective action plans now in order to restore request for anticipated payment privileges. The HHH MAC has received 50 CAPS and rebuttal letters so far, a Palmetto spokesperson tells Eli.

Reminder: Palmetto notified HHAs with 100 or more auto-canceled RAPs from Jan. 1 to April 15 that it would no longer pay their RAPs, just their final claims, the Palmetto spokesperson says. Palmetto also will be sending a notice to 469 other agencies with elevated RAP auto-cancel levels, "to encourage them to review their billing practices in order to become more timely in the submission of their final claims as required by the home health billing requirements set forth by" the Centers for Medicare & Medicaid Services, the Palmetto source explains.

This actually isn’t the first time Palmetto has acted on this issue, the spokesperson says. "We’ve monitored the situation of providers filing RAPs with no finals for some time," the source explains. "We’ve taken similar action on a more targeted basis in the past. We took this broader action in an effort to encourage providers to follow the home health billing instructions outlined in the CMS manual."

For agencies sending in CAPs, the plan "should include a statement of the problem or weakness that caused the delay in filing final claims, include proposed solutions to the problem, and state who is responsible for the monitoring [of] the CAP," the spokesperson explains. "We’ll review each CAP on a case-by-case basis depending on the provider-specific circumstances."

Palmetto is working on refining its process for selecting whose RAP privileges it revokes, reports the National Association for Home Care & Hospice. For example, it plans to consider agencies’ percentage of auto-canceled RAPs, not just a number, the trade group says.