In July we alerted you that CMS was considering a proposed rule that all Home Health Agencies (HHAs) submit a one-time submission of a Notice of Admission (NOA) within 5 calendar days of the start of care to establish that the beneficiary is under a Medicare home health period of care. The NOA would allow other providers and the CMS claims processing systems to know that the beneficiary is getting home healthcare.
CMS has now finalized that rule! Thanks to those of you who commented in support of the rule along with PTPN, APTA and other stakeholders. Beginning in 2021, CMS will require HHAs to submit a notification to CMS within 5 calendar days from the start of care or face a financial penalty. In 2021, it is called a Request for Anticipated Payment (RAP), and in 2022 and beyond, it is called a NOA. The policy in terms of timing/penalties for both the RAP and NOA are the same.
This has been a long journey. Last summer (2018) PTPN and PPS conducted a survey to collect information about the magnitude of claim denials due to the beneficiary being under a home health plan of care. The data was quite compelling and was shared with CMS. Then, in March of this year, CMS asked if we could share the claim numbers for instances when you received claim denials because the patient was under a home health plan of care. CMS indicated this information would be useful as it examined whether it should start requiring HHAs to submit a NOA within a certain number of days after the beneficiary is admitted. Our members came through and we gave CMS data on these denials.
This new policy should let the MACs (e.g. Noridian, Novitas, Palmetto, etc.) post this information on their portals. Then when you check the portal, you’ll see that the patient is receiving home healthcare much sooner than under the current system. We would expect that this will have the effect of cutting down Medicare claims denials, since you can then postpone the therapy treatment until the patient is actually discharged (and know who to contact about the discharge).
This is a great example of how working together we can impact policy. As we always say, together we can make a difference.