Home Health & Hospice Week

Hint: RCD readiness will help with PDGM.

With the Patient-Driven Groupings Model taking effect in just a few weeks, the vast majority of home health agencies’ resources are focused on that paradigm-shifting change. But you need to clear some space in your calendar for Review Choice Demonstration preparation too.

The RCD program is already up and running in Illinois and Ohio, and is set to take effect in Texas on March 2 and in Florida and North Carolina on May 4 (see Eli’s HCW, Vol. XXVIII, No. 38). Mercifully, the Centers for Medicare & Medicaid Services pushed back those start dates from earlier announced December and March dates, respectively.

HHAs in the three states on deck for RCD may have put the topic on the back burner while pursuing PDGM readiness. But RCD preparation needs to come to a boil sooner than they might think — especially for Texas.

And actually, all HHAs would benefit from undertaking PDGM prep sooner rather than later. “It’s never too early to prepare for RCD,” maintains reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. Providers that improve their systems in the preparation process “will be better positioned not only for RCD, but also PDGM.”

Consider this expert advice to get ready for medical review of every single claim under RCD:

1. Shift your perspective. You may feel like RCD will be a paperwork hassle, but your documen­tation content surely will hold up to claim-by-claim scrutiny. That attitude could be your downfall under the intensive review process. HHAs should “assume they are not fully compliant” with documentation and coverage standards and start preparations from there, urges National Association for Home Care & Hospice President William Dombi.

2. Review your knowledge. “HHAs should examine their knowledge levels of coverage and documentation standards,” Dombi tells Eli. You can’t comply with the rules if you are fuzzy on the details.

3. Increase your knowledge. “Take advantage of any education on RCD now,” urges Rachel Hammon with the Texas Association for Home Care & Hospice. That will help you plan what resources you’ll need for implementation, Hammon offers.

If your initial knowledge review reveals any deficits, target those topics for specific education.

Resource: For RCD information including workshop handouts, frequently asked questions, and registration for upcoming RCD events, go to Palmetto GBA’s RCD website at www.palmettogba.com, click on “Jurisdiction M Home Health and Hospice MAC” in the right column, then click on “Review Choice Demonstration” in the “Top Links” box on the left.

4. Audit yourself. To see where you stand, you should “conduct an internal audit on compliance,” Dombi advises.

Focus areas should be the “typical troublesome areas” for HHAs, Little suggests: “face-to-face certification completeness and compliance and obtaining physician signed documentation.”

In particular: HHAs should “review their processes for generating and obtaining signed physician plans of care,” recommends Joe Osentoski, reimbursement recovery & appeals director with Quality in Real Time in Sterling Heights, Michigan. Securing that documentation is “critical to getting claims processed under RCD Choice 1 (Pre-claim review),” he explains.

5. Fix your holes. Your internal audit should bring to light any areas that need strengthening. Many providers will need to “rework their care plan documentation to ensure coverage standards are supported,” Dombi says.

Little suggests a step you may already be undertaking for PDGM preparation. Look “for ways to streamline the front end operations of completing the initial onboarding of a patient at start of care and continuing care at recertification,” he advises.

Providers should “put in place a review process for physician face-to-face documentation at time of admission,” Osentoski stresses.

6. Check back after PDGM starts. Don’t assume your RCD prep is complete if you’ve undertaken all these steps already. “Ensure education closer to the implementation date as the process for RCD will be different under a PDGM payment model,” Hammon advises. “The intermediary may have updated information agencies need to know for a successful transition.”

7. Submit your choice. When CMS postponed RCD in Texas in October, review choice selection was already in progress. CMS ended that process on Oct. 21, and now says it will reopen the choice selection process on Jan. 15.

If you already made your choice between Choice 1 (Pre-Claim Review), Choice 2 (Post-payment Review), and Choice 3 (Minimal review with a 25 percent payment reduction) in Palmetto’s RCD system, “you will not need to make a new selection when the selection period opens back up on January 15, 2020,” the MAC explains on its website. But if you want to change your mind, “you will be able to make changes as desired through February 13, 2020,” Palmetto assures Texas providers.