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CMS Proposes to Require a Notice of Admission

Posted on Monday, July 29, 2019 12:45 PM

CMS is proposing to discontinue the advance, split percentage payments for all home health agencies in 2021.  As a result, agencies will no longer have to file Requests for Anticipated Payment (RAPs).

A RAP submission opens a home health prospective payment system (HHPPS) episode in the CMS Common Working File (CWF) which identifies the filing agency as the primary agency.  Elimination of the RAP means that CMS will need a new mechanism to update the CWF.

“CMS proposes to require HHAs submit a notice of admission (NOA) that will open a home health period under PDGM.  The proposal would require that:

  1. An HHA submit the NOA for the initial 30-day period. Subsequent episodes and a discharge from the HHA will be identified by the applicable patient status codes currently used on claims.
  2. HHAs submit the NOA within 5 days of the admission to home health services.
  3. Failure to submit a timely NOA would result in a reduction to the 30-day Medicare payment amount, from the start of care date to the NOA filing date.
  4. The payment reduction would be 1/30th off of the full 30-day period payment amount for each day until the date the NOA is submitted.
  5. In the event that the 30-day period results in a LUPA, visits rendered prior to the submission of the NOA would not be paid. CMS does not indicate whether a claim could be reduced from a 30-day unit to a per-visit LUPA if an NOA is submitted late.
  6. CMS proposes the NOA to be submitted through electronic data exchange (EDI) to Medicare contractors similar to the hospice Notice of Election (NOE).”

A timely NOA is needed in order to enforce consolidated billing requirements and to prevent Medicare from paying the wrong providers/suppliers for services.

Source: NAHC Report

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