Home Health & Hospice Week

More than a third of Texas agencies have entered their RCD choice so far.

Pre-Claim Review should be a no-brainer for most home health agencies undergoing the Review Choice Demonstration, and the latest group of HHAs to make their selections for the demonstration reflect that.

Reminder: RCD is a medical review demonstration project. Agencies can choose from Option 1: Pre-Claim Review (PCR) of 100 percent of claims, Option 2: Post-Payment Review of 100 percent of claims, or Option 3: Minimal Review with a 25 percent payment cut and potential Recovery Audit Contractor referral. Advanced review options are available later. RCD is currently operating in Illinois and Ohio, and will begin in Texas in March and Florida and North Carolina in May.

PCR is clearly the most advantageous review method for nearly all HHAs, experts stress. It allows “the opportunity for documentation to be reviewed on a pre-claim basis rather than a post-claim basis to avoid potential payment denials,” points out M. Aaron Little with BKD in Springfield, Missouri.

In other words, HHAs can receive pre-claim non-affirmations, correct the documentation or other problems when possible, and resubmit a claim successfully.

It’s surprising that any HHAs would choose the post-pay review option, judges Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan. “This is the equivalent of a 100 percent Additional Development Request (ADR) review — conducted after service has been provided,” Osentoski emphasizes.

Texas HHAs appear to agree, because a whopping 95 percent of them have selected Option 1:PCR so far, HHH Medicare Administrative Contractor Palmetto GBA reports in a new post on its website. In contrast, only 4 percent of Texas providers have chosen Option 2: Post-Pay Review and 1 percent Minimal Review. The RCD selection period for Texas closes Feb. 13, so those ratios may — and likely will — change, a Palmetto spokes­person confirms.

As of Jan. 22, “roughly 36 percent of providers who billed within the last six months have made a choice” and entered their selection, reports Rachel Hammon with the Texas Association for Home Care & Hospice. “Currently there are about 2,098 provider numbers in Texas according to Texas Health and Human Services data,” Hammon tells Eli.

“I’m not surprised by the strong selection of Option 1,” Little says. It seems the best choice for “providers in Texas who haven’t yet lived through any kind of PCR/RCD process,” he observes. “Texas is a very diverse state of providers and I think there will be a significant learning curve with RCD.”

Passive HHAs Skew Option Stats

The results for Texas so far differ from those for the last state to undergo RCD, Ohio. When Ohio HHAs had a chance to enter their review selection before the demo began there on Sept. 30, 2019, 14 percent chose Option 2: Post-Pay Review and 2 percent chose Option 3: Minimal Review, Palmetto explains on its website.

However: Those stats look very different when you consider the Ohio agencies that did not enter an RCD review option at all. Nearly one-third of HHAs — 210 of 667 eligible agencies in the state — did not enter their method selection. Palmetto automatically placed all those that did not make a selection into Option 2: Post-Pay Review. That means 58 percent of Ohio agencies ended up on PCR, while 41 percent went on Post-Pay Review, Osentoski calculates.

It’s not yet known how many Texas HHAs won’t enter a selection, since the deadline is next month. But agencies that don’t make a choice and get placed in Post-Pay Review by default will be missing out on the big advantages of PCR, experts warn.

“I would expect that Choice 2 significantly increases when selection is all done,” Osentoski predicts.

Getting the word out: TAHC is working with the MAC on “what we can do” to increase the number of agencies that have entered their RCD choices “since the choice period ends Feb. 13,” Hammon says.

“Our advice is to choose PCR if Medicare HH services is your primary book of business,” Hammon adds.

The exception: “It would not be advisable for those agencies that may do primarily Medicaid home health services and rarely provide Medicare services to do PCR,” however, Hammon adds.