Home Health & Hospice Week

2. Get clear with your payors. CMS and the MACs have been clear about Medicare NOA rules, but what about managed care plans? “Check with any Medicare Advantage (MA) plans the agency deals with, since they may also follow this practice,” advises Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan. The change “may offer an opportunity for MA medical reviews to scrutinize it as well and adjust claims to recoup payment,” he warns.

One of the CMS Frequently Asked Questions on NOAs states that “you will need to contact any Medicare Advantage plans or other insurance plans to which [you] submit claims to find out the details of their billing requirements,” Osentoski notes.

3. Educate staff. Once you know what you’ll be required to do and have drawn up policies and procedures, train your staff on them.

Be sure to emphasize the specifics of counting the five-calendar-day deadline for NOA submission. “The requirement is within five calendar days, so coming into holiday weekends, staff will need to be on the bounce to prevent the non-appealable adjustment for late submission,” Osentoski counsels. “The start of care is Day Zero for counting when the NOA is due,” he highlights.

4. Have your affected patient list ready. “Providers should be printing off census reports and making a list with dates for those artificial NOA dates,” Warmack directs. Then you can make sure those NOAs with the correct dates get submitted punctually and correctly.

5. Don’t submit early. You might be hoping to get a jump on the affected cases by submitting as soon as NOAs take effect. That won’t work, experts warn. “NOAs cannot be submitted early, i.e., before the ‘From’ date reported on the NOA,” Palmetto GBA specifies on its website.

6. Don’t neglect final claims. “Agencies do need to keep in mind that while the RAP is gone, of course final billing must still be done for each 30-day payment period,” Osentoski reminds.

7. Prioritize quick NOA corrections. “It’s critical that providers understand if a NOA is billed but then returned with an error, they only have two calendar days to correct and resubmit (in most cases) to avoid a payment penalty,” Little stresses.

8. Learn from your no-pay RAP mistakes. “Those agencies that have done well to adapt to no-pay RAP requirements will likely do well with NOAs, but agencies that have struggled with no-pay RAPs will likely struggle with NOAs,” Little expects. If you fell into the latter category at the start of this year, be sure to set aside enough time and resources to make sure you prepare enough this time around.