Home Health & Hospice Week

CMS listens to reason just weeks after setting burdensome start date.

You may be getting ready to hand out candy to trick or treaters, but a newly announced delay to the Review Choice Demonstration will make hundreds of agencies’ December holiday seasons much less burdensome.

Change: On Oct. 2, the Centers for Medi- care & Medicaid Services announced RCD would commence in Texas in December and would start in March in Florida and North Carolina (see Eli’s HCW, Vol. XXVIII, No. 35). Now CMS has announced a delay to those dates, moving the Texas start date to March 2 and the other states’ implementation date to May 4.

The delay will “allow home health agencies to transition to the Patient-Driven Groupings Model,” CMS explains in an Oct. 21 website post.

CMS is full of surprises lately, notes Joe Osentoski, reimbursement recovery and appeals director with Quality in Real Time in Sterling Heights, Michigan. “After the surprise that CMS was moving forward with RCD in Texas prior to PDGM, it is surprising that this delay has now been implemented less than three weeks later,” Osentoski notes.

It is “a big sigh of relief to see CMS take a sensible step to defer implementation until after PDGM,” says reimbursement expert M. Aaron Little with BKD in Springfield, Missouri.

No one is happier than Texas HHAs about the development. “Delaying RCD implementation will prevent unnecessary and compounded delays in payments for Texas agencies that would have occurred with a dual rollout of a payment change (PDGM) coupled with a process change (RCD) that has proven to slow down billing,” says Rachel Hammon with the Texas Association for Home Care & Hospice.

The nearly joint RCD and PDGM implemen­tation was poised to wreak havoc on agencies particularly because it would have occurred during the already hectic holiday season. “During the holidays, when many physician offices are closed, obtaining the necessary signatures for RCD would be exceptionally difficult in a timely manner,” Hammon tells Eli. That would have caused “payment delays that would only be compounded by the start of PDGM.”

Why? PDGM will almost surely come with “unknown systems issues that will result in payment delays,” Hammon predicts.

The good news is that HHAs now “can get through the holidays and focus on preparing for PDGM, rather than scrambling and struggling to get through the holidays stressing about both PDGM and RCD,” Little comments. “The holidays are stressful enough for home health providers without having to prepare for the two biggest changes to their industry in the past 20 years,” he stresses.

Bottom line: Agencies in RCD states now “will have more time to focus on PDGM implemen­tation,” praises National Association for Home Care & Hospice President William Dombi.

NAHC attributes the delay to the advocacy efforts by NAHC, TAHC, the Association for Home & Hospice Care of North Carolina, the Home Care Association of Florida, and many other stakeholders. “We made a strong and logical case for the delay,” Dombi tells Eli.

Lobbying group the Partnership for Quality Home Healthcare praises CMS for listening to the industry’s concerns. “As the home health sector prepares for the largest payment model change we have experienced in two decades, this is a wise and prudent move,” PQHH Chair and LHC Group CEO Keith Myers says in a release.

The delay is undoubtedly good news, but HHAs in RCD states still need to gear up for RCD preparations. “RCD will still happen,” Osentoski cautions. Affected agencies “will just have a little time to assess how their PDGM preparation has worked out in early 2020, especially in gathering the information needed for timely billing.”

In particular, when RCD launches, “I can see cash flow presenting a challenge due to the significant changes of payment under PDGM along with the reduction of the RAP,” Osentoski cautions

Note: The delay announcement 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. For preparation tips for RCD, see a future issue of Eli’s Home Care Week.