Home Health & Hospice Week

Review Choice Demonstration:

RCD Pushes On While End Date Remains Unclear

Avoid PTAN mix-ups or risk hefty penalty.

Two states are getting ready to begin their next Review Choice Demonstration cycles, but just how long the program will continue is an open question.

In Texas, home health agencies will begin Cycle 7 on April 1, RCD contractor Palmetto GBA reports on its website. That means agencies must choose their review selection by March 15, the HHH Medicare Administrative Contractor explains.

“HHAs that do not make a selection during that time period will default to either Choice 2 or Choice 4,” Palmetto reminds providers. Choice 2 is 100 percent postpayment review and Choice 4 is selective postpayment review of a statistically valid random sample of claims every six months for the remainder of the demonstration.

In Illinois, HHAs will begin Cycle 8 on April 1, and also must make their review selections by March 15. Illinois is the state that has operated the longest under RCD.

As providers transition between cycles, “please be advised of the actions required when changing from one choice to another,” Palmetto advises. For example, agencies going from Choice 2: Postpay review to Choice 1: PCR should “continue to respond to ADRs,” Palmetto advises. At the same time, they should “begin submitting PCR requests on 4/1/2024 for any claim that will be submitted on or after 4/1/2024 with a date of service on or after 6/1/2019,” the contractor explains. Those PCR requests should include Unique Tracking Numbers (UTNs,), the MAC adds.

Meanwhile, HHAs continue to wait for word from CMS on whether RCD will continue past its May 2024 end date. Medicare officials have stayed mum on the prospect in the face of questions. Most recently, CMS did not respond by press time to a question on the matter from AAPC.

Beware: PTAN Mix-Ups Can Cost You Big

Watch out: Regardless of which cycle you’re in, “Palmetto GBA is seeing an increase of pre-claim review (PCR) submissions with incorrect Provider Transaction Access Numbers (PTANs), also known as CMS Certification Numbers (CCNs),” the MAC warns in a new post on its website.

“PCR requests are rejected when Palmetto GBA is unable to process the request due to incomplete or invalid information. This will cause delays in receiving a Unique Tracking Number (UTN),” Palmetto cautions.

Ouch: “Any final bill submitted with a PTAN that differs from the PTAN on the corresponding UTN will cause an Additional Documentation Request (ADR) to be generated which will require a response and be subject to the 25 percent payment reduction on the final allowed amount,” Palmetto details.

To fix an incorrect number, “the provider should submit a new initial PCR submission (not a resubmission) with the correct PTAN,” Palmetto instructs. “Both PCR requests will be included in the affirmation rate,” the MAC adds.

Do this: “Users who have linked multiple PTANs under one default ID through the Account Linking process must ensure they select the correct PTAN for PCR requests,” Palmetto stresses. “Users can easily switch between their linked accounts/PTANs by using the Provider dropdown box located near the top of each tab. Simply click on the dropdown box to display the list of all linked accounts available and select the desired provider account,” the contractor explains. v

Note: More RCD resources are at www.palmettogba.com/palmetto/jmhhh.nsf/T/Home Health Review Choice Demonstration (RCD)~Pre-Claim Review.

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