The Centers for Medicare & Medicaid Services (CMS) announced that its phase-out of requests for anticipated payments (RAPs) will be complete in 20221, simplifying the process of billing home health care delivered to Medicare patients by Home Health & Hospice Medicare Administrative Contractors (MACs). Instead of the RAP, home health agencies (HHAs) will submit a one-time notice of admission (NOA) to mark the beginning of a period of care.
Understanding the change
When billing Medicare contractors for home health care, HHAs currently have to submit one RAP for every 30-day period of care (POC) for the duration of the patient’s episode of care. With the full phase-out of RAPs, HHAs will begin submitting NOAs when billing Home Health & Hospice MACs. CMS will require HHAs to submit one NOA for any series of HH POCs, beginning with admission and ending with patient discharge. The NOA will cover contiguous 30-day periods of care. If a patient is discharged from home health care but later qualifies for home health services, the provider will have to submit a new NOA.
Billing with NOAs
Under the change, HHAs must submit a NOA within the first five days of a period of care using TOB 32A. After the NOA has been submitted, HHAs will use TOB 329 to report POC. As of Jan. 1, 2022, TOB 329 will be reclassified to an original claim from an adjustment. HHAs are able to submit NOAs to Home Health & Hospice Medicare Administrative Contractors by mail, Electronic Data Interchange or Direct Data Entry. When submitting NOAs through an Electronic Data Interchange, HHAs will need to submit additional data beyond the requirements of the NOA to satisfy CMS transaction standards.
ABILITY has adapted its applications to accommodate the billing change. As ABILITY EASE Medicare has done with hospice notice of election (NOE) claims, the application now allows users to submit NOAs in bulk through batch submissions. That allows providers to submit their NOAs on time to reduce timely filing penalties.
For patients who are already enrolled in home health care as of Jan. 1, 2022, HHAs must submit a one-time NOA listing an artificial admission date with the period of care beginning in 2022.
CMS will implement a reduction in payment for non-timely NOA submission. Payments will be reduced by 1/30 of the wage rate for each day past the five-day filing window that the NOA is late. If an HHA does miss the filing deadline, they are able to request an exception from CMS to avoid the reduction in payment.
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1. “Replacing Home Health Requests for Anticipated Payment (RAPs) with a Notice of Admission (NOA) – Manual Instructions.” MLN Matters, June 9, 2021. www.cms.gov/files/document/mm12256.pdf
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