Home Health & Hospice Week

Plus: Take note of this NOA billing change.

Get ready to say goodbye to RAPs and hello to NOAs with a minimum of disturbance — if you know the ropes ahead of time.

Recap: The Centers for Medicare & Medicaid Ser-vices first floated the idea of NOAs replacing Requests for Anticipated Payment in the 2018 rulemaking cycle. Commenters roundly criticized the proposal, but CMS went ahead and finalized NOAs in the 2019 final rule anyway (see HCW by AAPC, Vol. XXVIII, No. 39-40). Under the requirement, HHAs must submit an NOA within five calendar days of the start of care or lose reimbursement at the rate of 1/30th per day for every day the notice is late. CMS did give agencies an extra year, moving NOA implementation from January 2021 to 2022. CMS laid out the NOA procedures in a Medicare Claims Processing Manual addition and transmittal earlier this year (see HCW by AAPC, Vol. XXX, No. 18).

Now the three HHH Medicare Administrative Con-tractors — Palmetto GBA, CGS, and National Government Services — have issued joint NOA job aids: “Billing the Home Health Notice of Admission” and “Request for Anticipated Payment versus Notice of Admission.” The billing job aid “identifies required fields when billing the home health Notice of Admission,” MAC Palmetto explains. And it walks through all the steps for submission.

Important: “One of the key things … [is] the bill type,” says billing expert Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. “The bill type will be a 32A for a Notice of Admission, or a 32D if you’re trying to cancel that Notice of Admission,” Gaboury says in her latest “Monday Minute with Melinda” vlog post.

It’s also helpful to note that “the agency needs to admit the patient, and have a first billable visit to begin an episode” before submitting the NOA, notes consultant Linda Scott with Scott Solutions in Arlington, Virginia. “Any valid diagnosis code works” on the NOA too, Scott points out.

Another critical piece of information in the aid is how the NOA process will operate for episodes that span the Jan. 1 start date. “If it’s not a brand new start of care, but it’s a 30-day period … where the start of care was in 2021, you will need to file a Notice of Admission for that,” Gaboury highlights.

How it will work: “HHAs with periods of care that continue from 2021 into 2022 must submit an NOA with a one-time artificial admission date that corresponds with the ‘From’ on the new period of care in 2022,” the aid explains. “For example, if the start of care is 12.13.21, the first 30-day period of care runs from 12.13.21 – 01.11.22. You would need an NOA on 01.12.22 for a new period in CY2022,” it instructs.

Celebrate A Big Perk Of This Change

The good news is that while “the Notice of Admission is going to be required for every 30-day period beginning January 1, 2022 or later, you only have to do it once as long as the patient remains on service,” Gaboury cheers. That compares to the current requirement of a no-pay RAP for every 30-day period.

Going from once every payment period to once per admission “is really huge and should significantly reduce the number of billing transactions by providers,” lauds M. Aaron Little with BKD in Springfield, Missouri.

Other differences between the current RAP and the upcoming NOA, according to the RAP versus NOA job aid, include no patient control number required on the NOA; no source code required on the NOA (HHAs can use a default value of “1”); no patient discharge status required (HHAs can use a default value of “30”); no value code and amount required; no HCPCS, Accommodation Rate, or HIPPS Rate Code required (HHAs can use a placeholder code of “1AA11”); and no service date required.

Note: Links to the job aids are at www.palmettogba.com/palmetto/jmhhh.nsf/DID/9C6RZ83761 — scroll down to the Aug. 31 entry. The MLN Matters article about NOAs updated in June is at www.cms.gov/files/document/mm12256.pdf and the NOA Companion Guide issued in May is at www.cms.gov/files/document/home-health-notice-admission-837i-companion-guide-updated-06172021.pdf.