Home Health & Hospice Week

As with any type of medical review, the physician face-to-face encounter needs to be a major focus.

Recap: On May 17, two weeks before the five-year RCD demo was set to end, the Centers for Medicare & Medicaid Services announced that it was extending the project for an additional five years in the current demo states of Illinois, Ohio, Texas, North Carolina, Florida, and Oklahoma (see HHHW by AAPC, Vol. XXXIII, No. 18). The only change appears to be that RCD is dropping the “Choice 3: Minimal Review with 25% Payment Reduction” review option.

CMS and RCD contractor Palmetto GBA haven’t announced an expansion to other states, but experts believe that move is coming — and likely sooner rather than later.

With the extension and possible expansion in mind, experts recommend these steps for HHAs to survive and thrive under the model — either now or in the future:

For HHAs inside the current RCD states:

1. Keep your eyes and ears open. “In an RCD state, keep an eye out for additional transition guidance from Palmetto GBA,” advises consultant Joe Osentoski with Gateway Home Health Coding & Consulting in Sterling Heights, Mich. In fact, Palmetto has already issued an update on dates and choice option renumbering (see story, p. 147).

2. Stay tuned for hand-off policy change details. In addition to general RCD announcements, HHAs should be watching for clarifications on the controversial new physician hand-off policy Palmetto announced for RCD on May 14 (see HHHW by AAPC, Vol. XXXIII, No. 18). Under the new policy, which Palmetto said took effect on May 20, “home health agencies must submit a hand-off from any original certifying provider to a subsequent provider,” according to the MAC. That is “a significant change in policy,” says Mary Carr with the National Association for Home Care & Hospice.

Accordingly, “if there is a hand-off from one physician to another, make sure you have that in your documentation,” urges consultant J’non Griffin with SimiTree based in Hamden, Conn.

However: Multiple regulatory and compliance experts agree that there is no regulatory basis for this requirement. NAHC is seeking clarification from CMS, Carr tells AAPC.

3. Settle in in Oklahoma. When CMS let the clock count down to the May 31 end date without an extension announcement, it appeared that Sooner State HHAs would have to spend only a handful of months under the program. As a result, agencies strapped for time and resources may not have devoted much effort to optimizing operations for RCD.

Now, “agencies operating in Oklahoma [must] come to terms with the fact that RCD is here to stay — at least for the next five years,” stresses reimbursement expert M. Aaron Little with FORVIS in Springfield, Mo. They should “make sure that operations are streamlined and adapted to the RCD process,” Little advises.

4. Review policies and procedures. RCD agencies should “ensure that all staff are fully aware of and compliant with RCD requirements,” recommends Brian Lebanion with BC Healthcare Consulting in Corbin, Ky.

5. Update employee training. Agencies should “provide refresher training for staff on documentation and submission procedures to minimize the risk of claims being denied,” Lebanion offers.

6. Turn the microscope on yourself. Providers should conduct internal audits of current cases to identify — and rectify — any potential issues in cases under review, Lebanion advises.

If your agency is having trouble complying with all requirements, consider getting outside help, Griffin suggests. “It takes organization and time for agencies to submit the information to obtain a UTN [unique tracking number],” she tells AAPC. “Consider outsourcing the review of the information to make sure you are ready and have all the available information ready for submission.”

In particular, “always, always, always make sure you have a valid [face-to-face physician encounter] that matches the reason you are seeing the patient,” Griffin exhorts. And “since a signed plan of care needs to be submitted for UTNs, you will want to make sure your process for orders is a tight process,” she advises.

“Providers I have talked to in RCD states emphasized that the most important aspect of surviving RCD is having a process for gathering and submitting,” shares attorney Robert Markette Jr. with Hall Render in Indianapolis. “Once you have that process in place, it is more manageable,” he tells AAPC. “It’s still frustrating, but it’s manageable.”

8. Double-check your review choice. HHAs should “determine which RCD method is the best route for their agency in order to reduce cost and expedite reimbursement,” Lebanion counsels. Don’t forget the former Choice 3: Minimal Review with 25% Payment Reduction is now off the table.

9. Get on RCD prep right away. “I would recommend that states with Palmetto [but] not currently under RCD … start preparing for an expansion,” NAHC’s Carr recommends. With Palmetto already their regular Medicare contractor and the RCD contractor, expansion will be easier, and thus probably quicker, in those remaining 10 states.