Advanced Search

Home Health & Hospice Week

Strategy:

Follow These 8 Crucial Tips To Improve Your No-Pay RAP Process

Published on Fri Mar 19, 2021

RAP submission within 24 hours is possible, billing expert maintains.

No-pay RAPs can cost you in time and resources — not to mention outright payments. Be sure you’re doing as well as you can under the new mechanism with advice from the experts.

Consider these lessons learned so far in 2021 about no-pay request for anticipated payment:

1. Educate yourself. The Centers for Medicare & Medicaid Services hasn’t done a stellar job of communicating RAP differences to home health agencies, experts agree. Combat that by reading up on materials ranging from final payment rules to HHH Medicare Administrative Contractor guidance to Medicare manuals.

Helpful: A newly issued question-and-answer docu-ment compiled by all three MACs combines most of that information into one handy source. The 25-question, 11-page document addresses a range of topics including what’s dif­ferent about no-pay RAPs, how appeals of penalties for late RAPs work, and deadlines down to the hour. See the tool at https://www.palmettogba.com/Palmetto/Providers.Nsf/files/Multi_MAC_2021_Penalty_for_Delayed_RAP_Submission_Final_022321.pdf/$File/Multi_MAC_2021_Penalty_for_Delayed_RAP_Submission_Final_022321.pdf.

2. Use a dummy HIPPS code. The only practical way to get your no-pay RAP in by the five-day deadline is to use a placeholder HIPPS code instead of the real one. The electronic medical record “could assign any valid HIPPS code for the RAP submission,” notes McBee Associates in its online blog. But the HIPPS code on the RAP and final claim must match, even when you know it’s not the correct one. “The grouping to determine the HIPPS code used for final payment will occur in the Medicare systems,” the MACs say in their Q&A. “At that time, the submitted HIPPS code on the claim will be replaced with the system-calculated code.”

“Once your RAP is submitted within the five-day window, you can continue your internal review process for OASIS accuracy and ICD-10 coding,” McBee notes.

3. Weigh which principal diagnosis code to use. If you wish, you could use a dummy diagnosis code on the no-pay RAP too. “We do have a minority of agencies that have it a practice to drop a dummy primary diagnosis to avoid further delays in processing the RAP,” acknowledges Lynn Labarta, CEO of Imark Billing in Miami.

Unlike the HIPPS codes, diagnosis codes on RAPs and final claims do not have to match. However, the claims system uses the diagnosis codes on the final claim — including the pertinent secondary diagnoses — to calculate the final payment.

On the other hand, “agencies that have a good intake department [and] that understand coding ... will try to put the code in” from the start, offers consultant J’non Griffin with Home Health Solutions in Carbon Hill, Alabama. “This would be best practice, not only for the RAP, but also to help identify the real reason for home care for the clinicians,” Griffin says.

Required: “We encourage agencies to use a diagnosis from the referral,” says Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. “The key is that the diagnosis must be a valid PDGM diagnosis from the list of acceptable primary diagnoses,” Gaboury stresses.

4. Submit RAPs well ahead. Medicare gives you five days from the start of care to file the no-pay RAP. But weekend days count, and RAPs filed after 5 p.m. ET on weekdays are credited to the next day, the MACs clarify in the Q&As. Also, returned or rejected RAPs you resubmit are still under the same five-day deadline — the clock doesn’t restart.

To be safe, “ensure that you are filing the RAP by day 3 of the period,” Gaboury recommends.

Even better, “with these new rules … we could set a goal to submit the RAPs on or within 24 hours after the admission date,” Labarta says. Remember, “we do not have to have the OASIS completed nor the plan of care sent to the physician,” she points out. “This lessening of the RAP submission rules really helps us be able to meet the 5-day submission requirements,” she explains.

Bottom line: “Providers really need to make certain their operations and revenue cycle teams are being diligent to make sure they are doing all they can to timely and accurately submit the no-pay RAPs,” Little advises.

5. Monitor the submission. The deadline is not met based on submission, but rather acceptance by the claims system, the MACs highlight in the Q&As. If a RAP is pro­cessed and approved, then “the date the RAP was received by the MAC” counts toward the deadline, they indicate.

But “if the RAP is Returned to Provider (RTP) for cor­rection, it will be given a new received date when it is returned for processing after correction,” the MACs say. This is why monitoring is so crucial for no-pay RAP success, emphasizes Nick Seabrook with BlackTree Healthcare Consulting in King of Prussia, Pennsylvania.

6. Identify and resolve the problem. When a RAP returns or rejects, be sure you understand why so you can resolve it, Seabrook recommends. If it’s due to one of Medicare’s documented claims glitches (see story, p. 84), you can file for a late RAP exception by appending the KX modifier to the HIPPS code reported on the revenue code 0023 line of the final claim, the Q&As instruct.

“The HHA should provide sufficient information in the Remarks section of its claim to allow the MAC to research the exception request,” the Q&As elaborate. One of four scenarios that qualify a claim for a RAP deadline exception is “an event that produces a data filing problem due to a CMS or MAC systems issue that is beyond the control of the HHA.”

Watch out: “Do not request an exception on a RAP,” the MACs urge. “This will cause the RAP to return and likely cause additional late penalty days to accumulate.”

If the return or reject is due to an error on your part, you can fix it and resubmit timely. Then you should look over your policies and procedures to eliminate the same types of errors going forward.

“The revenue cycle staff have to be diligent to watch for no-pay RAPs that might reject or be returned to provider that they have to address promptly to avoid payment penalties,” Little says.

“Don’t just adjust the balance or write the claim off,” Seabrook exhorts. Get to the bottom of why each one rejects or returns and keep track of them closely.

7. Submit both period RAPs at once. CMS intentionally set up RAP billing so that HHAs can bill both no-pay RAPs for a 60-day certification period at the start of the first 30-day billing period. “Ensure that you are sending both 30-day period RAPs at the beginning of the 60-day episode,” Gaboury urges. “In a recert situation, file the 30-day period RAPs as soon as the recertification order has been obtained,” she adds.

8. Educate your staff. It’s not just execs who need to understand the new no-pay RAP rules. Providers “should talk to their staff and educate the team so that they understand the new RAP submission guidelines,” Labarta encourages. You should spell out the new ability to submit RAPs based only on a verbal or written physician order, after the start of care visit is complete. “This is very different than the requirement prior to 2020,” she emphasizes.

Under the new rules, “you have to have a really good billing department with good processes in place,” Griffin cautions.

Note: CGS’s primer on billing RAPs, including filing for exceptions and more details, is at https://cgsmedicare.com/hhh/education/materials/anticipated_payment.html.

Other Articles in this issue of

Home Health & Hospice Week

View All