Home Health & Hospice Week

Medicare wants you to submit RAPs under RCD, but may punish you for it.

Don’t consider yourself on vacation from RAPs, if the Review Choice Demonstration comes to your state. Multiple questions in a recently updated Frequently Asked Questions document address the issue.

Question: “If we select PCR, do we need to submit our Request for Anticipated Payment (RAP) and allow it to process before submitting our documentation for PCR?” one agency asks in the FAQs.

Answer: “Providers are encouraged to submit the RAP and allow it to process prior to submitting the PCR Request. This will allow the beneficiary record to open on the Common Working File,” the Centers for Medicare & Medicaid Services responds.

But you’d better be pretty sure you can back up that RAP with a fully documented claim — including securing physician paperwork — or risk cash-flow draining RAP suspension.

Question: “If we auto cancel our Request for Anticipated Payment (RAP), could that put us on Zero RAP pay?”

Answer: “Yes, CMS tracks data for both auto cancels and manual cancels and the Zero RAP pay process will still apply during the RCD demonstration,” the agency replies.

And remember, if HHH Medicare Adminis­trative Contractor Palmetto GBA denies your final claim, you have to give the RAP money back.

Question: If a home health claim is denied after receiving a non-affirmative pre-claim review decision, will the Request for Anticipated Payment (RAP) be recouped as an overpayment?” an agency asked.

Answer: “The MAC will follow their standard procedures to recoup a RAP for any denied claims.” In other words, yes.

Reminder: A transmittal from CMS last year and multiple articles posted by MACs indicate they are monitoring RAP cancellation rates closely in advance of RCD and the coming Patient-Driven Groupings Model. Experts suggest keeping RAP cancellations under 25 percent to stay on the MACs’ good sides (see Eli’s HCW, Vol. XXVII, No. 35).  

Note: The FAQs are at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demonstration/Downloads/RCD-FAQs.pdf. The transmittal is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R817PI.pdf.