Home Health & Hospice Week

PDGM + RCD will close doors, expert warns.

An Oct. 2 announcement from Medicare has dashed Texas providers’ hopes of getting some PDGM breathing room before being forced to tackle the onerous Review Choice Demonstration project.

Just in time for the hectic holiday season, the RCD medical review program “will begin in Texas on December 2, 2019, and all episodes of care starting on or after this date will be subject to the requirements of the choice selected,” the Centers for Medicare & Medicaid Services says on its RCD webpage. “The choice selection period will begin on October 16, 2019 and end on November 14, 2019 for Home Health Agencies (HHAs) located in Texas, who submit claims to Palmetto GBA.”

Background: RCD, a slightly revamped version of the previous Pre-Claim Review demonstration, began in Illinois in June and has just launched in Ohio, as of Sept. 30.

Further, “the demonstration is expected to begin in North Carolina and Florida on March 30, 2020,” CMS says. That takes into account a “pause” for RCD implementation “to allow for the transition to the Patient Driven Grouping Model,” it says.

Launching RCD in another state before the paradigm-shifting PDGM scheduled for January is an unwelcome surprise for many, including National Association for Home Care & Hospice President William Dombi. “We were hoping that CMS would give all of the three states an RCD reprieve until the PDGM dust settles,” Dombi tells Eli. “A start of RCD in Texas just 30 days before PDGM does not respect the complexity and intensity of bringing PDGM into operation.”

And it’s actually less than a month at 29 days, points out Rachel Hammon with the Texas Association for Home Care & Hospice. “We are exceedingly disappointed at CMS’s decision to move forward with RCD in Texas so close to the roll out of PDGM,” Hammon tells Eli. “CMS seemed to recognize the wisdom avoiding the heavy burden of both RCD and PDGM at the same time in postponing further expansion into Florida and North Carolina until March 30, but did not extend the same recognition for Texas agencies.”

Many observers thought North Carolina would be the next state on the list, instead of the more populous Texas. “This seems like a poor decision by CMS to implement RCD in the state that has the most Medicare home health providers ... before PDGM,” stresses reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. “This will create a significant strain on PGBA’s resources at a time that is concurrent with the most significant change in Medicare home health payment in the last 20 years.”

And it’s even worse, because the month-ahead start date is deceptive, cautions Joe Osentoski, reimbursement recovery and appeals director with Quality in Real Time in Sterling Heights, Michigan. “Due to the inherent delays to obtain required record content (such as signed plans of care, certification requirements), those agencies choosing RCD Choice 1 (100 percent pre-claim review) will be starting or just starting to make submissions before PDGM is upon them,” Osentoski explains. “That may cause significant issues of maintaining cash flow and managing this additional administrative burden while managing the transition to PDGM.”

The result: “Texas is in effect implementing both RCD and PDGM simultaneously: a Texas-sized challenge,” Osentoski emphasizes.

HHAs need some relief from multiple drastic changes hitting at the same time, Dombi insists. “The burdens of PDGM are already on the shoulders of HHAs. Giving just 30 days before full-fledged PDGM is asking too much if CMS expects HHAs to do what is needed correctly,” he contends.

CMS does leave the door open a crack to bumping the March 2020 start dates for Florida and North Carolina. “CMS will monitor the transition to PDGM and assess the need for any change to this date,” the RCD webpage says.

But observers don’t hold out hope that CMS will budge from its intended date — even though it should. “Agencies will still be sorting through PDGM’s effect when RCD will be implemented” in March in those states, Osentoski expects.

Meanwhile, Texas agencies and their representatives aren’t giving up yet. “The combination of PDGM and RCD so close together (within 29 days) will have a devastating impact on agency cash flow and operations, forcing many agencies out of business and creating needless access to care issues for seniors who need this critical care at home,” Hammon warns. “CMS should delay any further roll out of RCD until March for the three remaining states and gather data from the Ohio implementation before rolling out RCD to Texas, Florida, and North Carolina — especially in the wake of PDGM,” she urges.

Note: The notice 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.