Home Health & Hospice Week

Don’t discount PDGM’s exacerbation of the pre-claim review program’s impact.

Illinois home health agencies are furiously gearing up for the Review Choice Demonstration’s June 1 start date in that state. But HHAs in other states can’t afford to just sit back and watch.

The RCD prior authorization project will take a heavy toll on Illinois agencies, observers predict. But RCD’s “impact will be much greater on the states that follow Illinois, since Illinois has already gone through Pre-Claim Review,” believes reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. The other four demo states are Ohio, Texas, North Carolina, and Florida.

Reminder: The Centers for Medicare & Medicaid Services halted the PCR demonstration in August 2017, after it significantly reduced home health spending in that state. On April 3, CMS announced the new preauthorization demo, RCD, would start in Illinois June 1 (see Eli’s HCW, Vol. XXVIII, No. 13).

There’s no doubt that RCD will slow down and/or reduce cash flow, notes Joe Osentoski, reimbursement recovery & appeals director with Quality in Real Time in Troy, Michigan. And it will consume resources due to “the inescapable need to alter business practices and agency processes to accommodate their RCD choice,” Osentoski adds.

Another complicating factor for later RCD states may be the Patient-Driven Groupings Model. CMS says it will give 60 days’ notice before implementing RCD in subsequent demo states. If CMS waits a few months to see how RCD is going in Illinois, then announces a start date two months away, an October or November start date would be expected.

“Any state that has to undergo both [PDGM and RCD] at the same time, or close together, will have a significantly greater challenge to maintain service and cash flow,” Osentoski predicts. Even if CMS waits six or eight months to get the next RCD state online, it would still put the demo’s start date at the same time or very shortly after PDGM’s.

On the other hand: Agencies in the subsequent RCD demo states have an advantage, however, Osentoski points out.

Demo states following Illinois “should benefit from all the data, feedback, and education provided from Illinois implementing RCD,” Osentoski tells Eli. Seeing how Land of Lincoln HHAs are treated and react to the demo and demo contractor, Palmetto GBA should prove valuable and will make the program’s onset “less of an initial shock,” he says.

In other words, “Illinois gets to put its toe in the water so following states can dive in,” Osentoski summarizes.

Follow These 3 Tips For RCD Success

While Illinois agencies are prepping at hyper speed, HHAs in other demo states — and even those states not yet named in the demonstration — can take these steps to minimize disruption when RCD comes their way:

1. Educate yourself. “There is substantial supporting material online and via teleconferences, and taking this content along with the Palmetto GBA informational notices and conferences should allow following states to prepare,” Osentoski advises.

2. Get to work. It’s never too early to start working on the underlying issues that will make or break your agency under RCD. “Prepare now by working on those key areas most impacted by RCD,” Little urges. Those include documentation accuracy, and timeliness and thoroughness of the orders management process, he says.

3. Be poised to act. HHAs must know when the implementation will take place in their state before they can map out a detailed training plan, Osentoski notes. But staying informed and sketching the outline of an implementation plan can save time and effort when it’s time to pull the trigger, experts say.

Note: RCD info, including the new Operational Guide, is at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demonstration/Review-Choice-Demonstration-for-Home-Health-Services.html. Palmetto’s RCD page is at www.palmettogba.com/palmetto/providers.nsf/docsCat/Providers~JM Home Health and Hospice~Home Health Review Choice Demonstration.