Home Health & Hospice Week

Review Choice Demonstration:

Agencies In Newest RCD State Must Nail Down Review Option Pronto

Newly revealed demonstration stats are likely to lead to an extension.

Keep an eye out for an extension of the Review Choice Demonstration — and that extension is likely to come with an expansion too.

The Centers for Medicare & Medicaid Services already has expanded RCD to Oklahoma effective Dec. 1, noted CMS’ Emily Richmond in the agency’s Oct. 11 Home Health Open Door Forum. It joins “the existing demonstration states of Illinois, Ohio, Texas, North Carolina and Florida,” Richmond reviewed.

Oklahoma home health agencies have from Oct. 16 to Nov. 15 to submit their RCD review option choices, Richmond added. They can choose pre-claim review, post payment review, or a “minimal post payment review with a 25 percent payment reduction, which means 100 percent of those claims have a 25 percent payment reduction,” she explained.

“All home health episodes of care beginning on or after Dec. 1 will be subject to the requirements of the review choice selected,” Richmond specified. Oklahoma HHAs that choose the PCR option can start submitting those requests on Dec. 1 as well, she noted.

One forum attendee hoped that CMS would be conducting some education with home health referral sources about the Oklahoma expansion. “Has there been any outreach to referral sources such as physician offices since this is a fairly new demonstration in the state of Oklahoma?” asked the provider.

A CMS official replied that the agency and RCD Medicare Administrative Contractor Palmetto GBA have been providing education for home health agencies in the state. But “physician offices are referral sources” and “agencies in Oklahoma will have to go back and forth with [them] to get documentation about the face-to-face visit,” the provider explained to CMS.

The CMS staffer said she would look into the matter.

Meanwhile, that CMS source did acknowledge that RCD is set to end on May 31, 2024. “But CMS is currently working internally to determine if the demonstration will be extended past that May expiration date,” she disclosed. If it decides to extend, “we will definitely provide ample notice,” she pledged. “At this point that’s about the best answer I can give,” the CMS official added.

In the National Association for Home Care & Hospice member listserv, NAHC’s Mary Carr notes that “the next steps will likely depend on the results of the demonstration.”

In an updated statistics sheet of RCD and its results thus far, CMS notes that it has affirmed 96 percent of pre-claim review requests under the demo in fiscal years 2021 and 2022. The percentage of approved requests for pre- and postpay review are lower — 76 percent in FY 2021 and 86 percent in FY 2022, according to the sheet.

Review time lengthens: Meanwhile, the time it took Palmetto GBA to review PCRs doubled from 2021 to 2022, going from 3.1 days to 6.3 days.

The rate of determinations overturned on appeal also doubled, although they remained very small at .03 percent in 2021 and .06 percent in 2022.

Nevertheless, the MAC accuracy rate for RCD improved slightly from 99.2 percent in 2021 to 99.5 percent in 2022, according to CMS. To determine that accuracy rate, “CMS’s Medical Review Accuracy Contractor (MRAC) reviews a sample of MAC prior authorization and pre-claim review decisions to determine the accuracy rate for each program,” the stats sheet explains.

Note: The updated stats are in the sheet at www.cms.gov/files/document/prior-authorization-and-pre-claim-review-program-statistics.pdf.

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