Posted Monday, March 31, 2021
Centers for Medicare & Medicaid Services (CMS) plans to eliminate the Request for Anticipated Payment (RAP) submission requirement at the end of 2021 and replace it with the Home Health Notice of Admission (NOA) beginning in 2022. The NOA will provide ongoing means for establishing the home health benefit and enable CMS to ensure compliance with consolidated payment rules. Elimination of advance payment necessitates agency cash flow planning.
As of January 1, 2022, the NOA submission will be required one time at the start of home care services within 5 days from the initial start-of-care (SOC) visit. The good news is that the one-time NOA submission will cover continuous 60-day episodes of home health care through discharge, reducing the 30-day RAP coverage period burden.
Along with basic beneficiary information, under the new rule the HHA must:
a. have a valid verbal order that specifies the skill and services to be provided during the initial visit, and
b. have completed the initial SOC visit.
A late NOA submission, defined as 5 days after the initial visit, is penalized at 1/30th of the expected payment per day applied from the date of admission which represents a potential loss of 20% or more; this will particularly affect you if non-billable visits reduce the full payment to a Low Utilization Payment Adjustment (LUPA).
What You Can Do Now
Prepare for NOA 2022 by:
1. continuing to run effective, compliant operations.
2. maximizing the use of EMR tools for managing referrals, timely admissions, and front-end, pre-billing processes.
3. continuing to meet Condition of Participation (CoP) requirements throughout the course of care; the CoP requirements have not changed.
Questions? Contact a Corridor expert about these or other requirements, regulations and operational practices affecting your compliance or cash flow,
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