Making sense of the new No Pay RAP

The Centers for Medicare & Medicaid Services (CMS) is taking the final step in eliminating up-front payments for services rendered across the healthcare industry. A new No Pay RAP (Request for Anticipated Payment) policy for home health providers begins January 1, 2021.

While CMS has relaxed the criteria for RAP submission, many home health agencies remain concerned about how to protect their revenue cycle and stay in compliance with the new policy.

8 things to know for 2021

Under the new rule, there will no longer be a payment associated with the RAP, and a late submission penalty has been added.

Because of these changes, CMS has lessened the requirements for submitting the RAP in 2021:

  • There are only two criteria for RAP submission: 1) a written or verbal physician’s order and 2) documentation of an initial visit and admission to home health care
  • A completed OASIS assessment and established plan of care will no longer be required prior to submitting the RAP
  • Only a principal diagnosis code is required on the RAP – secondary diagnoses are optional

The No Pay RAP rules that will impact home health payments for 2021 include:

  • RAP reimbursement will decrease from a 20% split payment to zero
  • Claims without RAPs will not be paid
  • A “non-timely submission payment reduction” for every day the RAP is late when not submitted within five days of the start of care date
  • For 60-day episodes of care, RAPs for both the first and second 30-day periods may be submitted at the same time
  • Any delays in claims submission will push back the payment cycle

How to protect your revenue cycle

While home health providers have come to rely on the split-payment model to keep cash flow stable, it is imperative to adjust billing processes as soon as possible to remain solvent, especially while operating under the Patient-Driven Groupings Model (PDGM).

Here are 5 steps your agency can take to avoid unnecessary payment reductions in 2021:

  1. Ensure the start of care visit is completed and documented as early as possible
  2. Make sure accurate coding is completed expediently
  3. Submit every RAP within five days of the start of care
  4. File claims after the first 30 days of every episode of care
  5. Ensure billing compliance by using claims management software that stays up to date with CMS regulations

ABILITY helps home health agencies achieve a seamless revenue cycle with claims management and analytics technology that aligns with regulatory requirements. Position your organization for revenue success by requesting a demo today.


Source: “Penalty for Delayed Request for Anticipated Payment (RAP Submission – Implementation),” MLN Matters 11855, CMS, October 27, 2020,

How does home health billing work?

While healthcare profit margins continue to dwindle, the aging population increases. According to the U.S. Census Bureau, by 2030, adults aged 65 and older will outnumber children under the age of 18 for the first time in history!1 That makes it imperative that home health, hospitals, physicians’ offices, and other healthcare organizations find ways to do more with less. Finding home health billing solutions that streamline the scheduling of physicians and nurses and shortening the turnaround time for Medicare payments is crucial. Learn how home health billing works to navigate the best practices for success.

Step 1: Getting approval for patient services

The first step in home health billing is to connect with the patient and the physician to identify the services needed. The next step is to determine financial responsibility for that care (e.g., any combination of Medicare/Medicaid, supplemental insurance and private pay). Medicare will generally only pay for home health services that involve nursing care, physical therapy, occupational therapy or speech therapy. Home or personal care assistance are generally not covered by Medicare or supplemental insurance plans. Patients also must be homebound and meet a variety of other requirements for 100% reimbursement. With an all-payer eligibility management system, you can manage multiple payers, tasks and activities as well as assign and prioritize patients to keep the billing process moving smoothly.

Step 2: Checking Medicare/Medicaid eligibility

Once you determine the services and timing required, and have assigned the correct billing codes, the next step is checking the patient’s eligibility with Medicare/Medicaid. Having access to Medicare’s HETS database will make checking eligibility much easier as it gives your staff real-time, detailed eligibility and benefits information at the onset of a patient’s stay. 

Step 3: Submitting the claims

Once care is provided, you will need to submit the claims to Medicare/Medicaid and to any supplemental insurance companies for payment. With all of the potential for human error in the billing process, automating your Medicare claims submissions can save you time and money. This efficiency can improve your cash flow and maximize your revenue. Automation helps eliminate ongoing follow-ups, reduces multiple contacts with payers and helps ensure the claims are processed without errors.

Step 4: Resolve denials

Because you are working with a variety of physician services, coding numbers, payers, and rules and regulations, there are bound to be times when claims are denied by either Medicare/Medicaid or private insurance. With powerful software solutions like ABILITY EASE All-Payer, you can automate the claims denial process and the correction of complex, multi-step claims. From a single dashboard, you can track appeals and communicate securely to resolve denials and improve cash flow. Automation can also free up your physicians and nurses so they can focus on seeing and treating more patients.

Step 5: Collect balance due from patient

An often overlooked, but important process in home health billing is to collect the balance due through patient payments. It’s important for patients to understand the bill, the itemized charges and the portion of the bill that was paid by insurance. Since only 50% of patients who experience billing difficulties pay their bill in full,2 it’s imperative to make patient payments as easy and convenient as possible.

Simplify your home health billing with ABILITY Network

Home health agencies have plenty to manage without having to worry about billing processes that can easily be upgraded from manual tasks to automated workflows. Whether it’s physician or nurse scheduling or researching denied claims, the powerful automated technology offered by ABILITY can help you. Give us a call today at 888.895.2649 and find out which software systems will work best for your needs. Or, request a no-obligation quote online. We’ll show you how we can increase your revenue cycle management and increase your cash flow!


1 “Older People Projected to Outnumber Children for First Time in U.S. History,” U.S. Census Bureau, March 13, 2018,

2 “How Patient Experience in Billing Offices Impacts Patient Payments,” Sara Heath, Xtelligent Healthcare Media, October 15, 2018,


ABILITY and design®, ABILITY® and ABILITY EASE® are trademarks of ABILITY Network, Inc.

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