Delta Connect Blog

CMS has proposed that the split payments made to home health agencies under the Request for Anticipated Payment (RAP) process will end in 2021.  As an interim step, no new home health care agency will receive RAPs in 2020 and home health agencies that have been in operation since prior to 2019 will receive 20% of the expected final payment amount in contrast to the 60% initial episode/50% later episode levels that have been in place since 2000.

Today, CMS announced the next state to participate in the Review Choice Demonstration (RCD) is Ohio beginning September 30, 2019.  CMS also stated it anticipates 60-90 days between beginning the demonstration in the remaining states of Texas, North Carolina, and Florida.

Medicare certified home health providers in Ohio will have from August 16 - September 15 to make their RCD choice selection via Palemetto GBA's eServices portal.  Since selections must be made through eServices, any Ohio provider not already signed up for eServices should do so now using the eServices portal link above. 

Ohio providers that do not make an RCD choice selection by September 15 will be automatically placed in Choice 2: Post-payment Review.

Home health providers will initially select between three review choices:

• Choice 1: Pre-Claim Review,
• Choice 2: Post-payment Review, or
• Choice 3: Minimal review with a 25% payment reduction
  • Those who select this choice will remain in this choice for the duration of the demonstration regardless of their claim approval rate.

Home health providers who select either Choice 1 or Choice 2 will be evaluated for six months. If the providers full affirmation rate or claim approval for those six months is 90 percent or greater (based on a minimum of 10 submitted pre-claim review requests or claims), the provider may select one of the three subsequent review choices.

• Choice 1: Pre-Claim Review,
• Choice 4: Selective Post-payment Review, or
• Choice 5: Spot Check Review

Home Health providers that do not actively choose one of the subsequent review option will automatically be assigned to participate in Choice 4: Selective Post-payment Review, and will remain there for the duration of the demonstration.

CMS has published a RCD HH Operational Guide that all providers affected by RCD should review.  There are also several other helpful resources for RCD available from Palmetto.  They are located at the Palmetto GBA Home Health Review Choice Demonstration webpage.

Last Friday, the Medicare Payment Advisory Commission (MedPAC) convened for presentations and discussions regarding the Medicare hospice and home health benefits.  The commission was presented information on current payment adequacy based on data from years past and suggestions from MedPAC staff for recommendations the committee will make to Congress for 2020.

The Centers for Medicare & Medicaid Services has issued a second Paperwork Reduction Act (PRA) notice for public comment for the Home Health Pre-Claim Review Demonstration (A.K.A. Review Choice Demonstration). This notice is for a 30-day public comment period.

On Monday evening, President Donald J. Trump signed into law  H.R. 6042, a bipartisan bill which passed Congress in July.  This bill allows states to delay electronic visit verification in Medicaid-reimbursed care services for one year.