Home Health & Hospice Week

Don’t accidentally get on 100 percent postpay.

Illinois home health agencies have only a few days left to choose their review option for RCD, or default to the 100 percent postpayment review option.

The Centers for Medicare & Medicaid Services will launch the Review Choice Demonstra- tion in that state June 1, and affected agencies have until May 16 to designate their review option via Palmetto GBA’s eServices portal, CMS reminds agencies in a message.

Reminder: All home health agencies in Illinois “were mailed a letter dated April 11, 2019, with your agency’s affirmation rate which was calculated during the Pre-Claim Review (PCR) demonstration,” Palmetto says in a new post on its website. Providers that did not participate in PCR, or did not achieve at least a 90 percent affirmation rate, may choose from three initial review options (100 percent prepay review, 100 percent postpay review, or “minimal review” with a 25 percent pay reduction). Providers that achieved a 90 percent or greater PCR affirmation rate may choose from the “subsequent” review options (“selective” postpay review of a random sample of claims every six months, “spot check” prepay review of 5 percent of claims every six months, or regular 100 percent prepay review).

If Illinois HHAs don’t designate a review option by the deadline, Palmetto will automatically slot them into 100 percent postpay review — even if they had a 90 percent or greater affirmation rate.

While RCD is expected to be a heavy burden, even for agencies that underwent PCR previously, some agencies in the demo will see another weight lifted. HHAs currently under a Targeted Probe & Educate review with Palmetto will be removed from the TPE when the RCD begins in their state, a Palmetto spokesperson confirms to Eli.

Likewise, providers under Unified Program Integrity Contractor review are “not eligible to make a Review Choice selection,” CMS says in a recently updated RCD question-and-answer set.

The Comprehensive Error Rate Testing program may review a claim that already underwent RCD review, CMS allows in the Q&As.

Excluded: “Low-Utilization Payment Adjustment (LUPA) claims with four or fewer visits are excluded from the Review Choice Demonstration for Home Health Services,” CMS says in another Q&A. Other exempt claims include those for Veteran Affairs, Indian Health Services, Part A/B rebilling, demand bills submitted with condition code 20, no-pay bills submitted with condition code 21, and Requests for Anticipate Payment (RAPs), CMS explains.  

Note: See the 101-question Q&A set at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demo­stration/Downloads/RCD-FAQs.pdf.