Posted on Monday, November 9, 2020

CMS has issued a change request to CR11855 – Penalty for Delayed Request for Anticipated Payment (RAP) Submission – Implementation. The Change Request (CR) revision added remittance advice message information related to the No Pay RAP penalty.

“Home health agencies (HHAs) should note that Medicare Administrative Contractors (MACs) will:

  • Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (loop 2100) on Home Health Claims on the 835 ERA o Group Code: CO o Claim Adjustment Reason Code (CARC): 95 (“Plan procedures not followed”)
  • Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (Loop 2320) on Home Health Claims to the 837I COB o Group Code: CO o CARC: 95 (“Plan procedures not followed”)   that  and we added that information to the article. We also changed the CR release.

The CMS No Pay RAP policy, effective January 1, 2021, will require home health agencies to submit the RAP within five days of the from date for each claim or a penalty will be applied to the final claim that  equals 1/30 of the 30 day period claim amount for each day the RAP is late.  Although CMS has relaxed the criteria for the submitting the RAP beginning in 2021, HHAs are concerned with their ability to comply with the No Pay RAP requirements and the submission time frame.”

Source: NAHC Report

 

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