Home Health & Hospice Week

Success depends on understanding new OASIS requirements.

To help keep your agency's cash flowing during the nine-day payment disruption at the end of this month, rely on request for anticipated payment (RAP) billing, but be sure you're billing correctly.

Beware Nine-Day Cash Drought

Background: Medicare will not pay any claims from Sept. 22 through Sept. 30, in accordance with the Deficit Reduction Act enacted in February, CMS announced in a May 10 MLN Matters article. Instead, intermediaries will pay these claims Oct. 2.

But RAPs are non-claim payments and thus not included in this cash flow crunch, the Centers for Medicare & Medicaid Services says. CMS revised its MLN Matters article about the hold after the Homecare and Hospice Financial Manage-
ment Association, an affiliate of the National Association for Home Care & Hospice, successfully challenged the inclusion of RAPs in the payment hold.

The impending late September payment hold for provider claims could cause "a serious nine-day cash flow problem," warns William Dombi, of NAHC's Center for Health Care Law. That's an especially potent threat for providers used to surviving from payment to payment, Dombi says in NAHC's online newsletter.

Temporarily Increase RAP Frequency

One way to avoid cash flow disruption in September is to bill RAPs more often, advises consultant Melinda Gaboury with Healthcare Provider Solutions in Nashville, TN.

More frequent RAP billing during September will "help step up cash flow prior to and during the nine days that final [claims] will not pay," Gaboury explains. For example, agencies that usually bill RAPs once or twice a week should bill daily, she advises.

New requirement: Effective June 21, CMS eliminated the requirement to lock the OASIS data within seven days of completing the assessment. But that change also eliminated the method agencies used to finalize OASIS data so they could bill the RAP.  
So just when they need RAPs the most, agencies are struggling with new submission requirements.

Resource: To ensure that you're submitting RAPs according to the latest requirements, review CMS' MLN Matters guidance on the topic at http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0643.pdf.

Reminder: Even though agencies don't have to submit OASIS data before billing RAPs, they do have to finalize the data first, says consultant M. Aaron Little with BKD in Springfield, MO.