Home Health & Hospice Week

Review Choice Demonstration:

Mandatory RCD Hits Florida, North Carolina

Will your state be next?

Even though COVID-19 numbers are skyrocketing, Medicare is shutting down its pandemic consideration for home health agencies in Review Choice Demonstration states.

Background: Last July, the Centers for Medicare & Medicaid Services announced it was ending on Aug. 31 the “pause” on the Review Choice Demonstration that had been in place since the beginning of the pandemic, even though originally it said it would wait until the end of the public health emergency to do so. After considerable political pressure, RCD contractor Palmetto GBA said it would “phase in” the demo in North Carolina and Florida, and it renewed the phase-in twice.

Now that COVID compromise is coming to an end. “Home health agencies (HHAs) in North Carolina and Florida will fully participate in RCD beginning on September 1, 2021,” Palmetto says on its website. “CMS will discontinue exercising the phased-in participation for HH RCD providers in these states,” the agency says on its RCD webpage.

Do this: Florida and North Carolina agencies will have a chance to change their review selections ahead of the resumption date. “If you would like to change your choice selection for the remainder of Cycle 2, you may do so during the selection window (August 1–15, 2021),” Palmetto instructs in a July 30 post. “If you initially made a choice selection for Cycle 2 and do not want to make a change to that choice selection, you do not need to take any action,” the HHH Medicare Administrative Contractor advises.

But some details of the resumption are still in play, one trade group indicates. “Effective September 1, 2021, all billing periods will be subject to the requirements of the review choice you selected. This will include any billing periods that have not yet been submitted as of September 1, 2021, with a date of service on or after the start of the demonstration in North Carolina and Florida (August 31, 2020),” Palmetto says in the notice.

“NAHC has reached out to CMS … as we do not believe it is CMS’ intent to apply the requirements in this way,” the trade group says in its member newsletter.

Note: More details are at www.palmettogba.com/palmetto/jmhhh.nsf/DID/B4HP2R8604 — scroll down to the article list by date at the bottom of the page for the latest information.

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