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 to check Medicare status quickly and easily

For physician practices, hospitals and all healthcare organizations, streamlining your revenue cycle management is critical. One of the best ways to recoup payments faster is with up-front Medicare eligibility checks. With the changes in the Affordable Care Act, patient responsibility is often in play and healthcare organizations who can communicate effectively with patients about how to pay for their medical treatment will be more successful at collecting full payments. At ABILITY Network, we offer a quick and easy way to check Medicare status online.

Why checking Medicare status is important

Medical benefits are always changing so it’s important to check the Medicare status of your patients often — whether it’s for prescription drugs or a specific procedure. This can cause a strain on some physician practices, care facilities, hospitals and other healthcare organizations. Save staff time and resources and quickly determine Medicare status with ABILITY CHOICE Medicare Eligibility. With 24/7 access to Medicare’s HETS database, your staff will be able to gather real-time, detailed eligibility status and medical benefit information, allowing you to:

  • Receive payments faster by verifying Medicare eligibility at the beginning of patient care
  • Reduce staff workload
  • Quickly identify Medicare replacement plans and secondary payers
  • Reduce denied claims with upfront identification of Medicare supplement or Medicare Advantage plans

How often should you check Medicare eligibility?

It’s important to check your patient’s Medicare eligibility throughout their course of treatment. Working with an information technology company like ABILITY can help reduce the time spent completing these frequent Medicare status checks. At the very minimum, you should check Medicare status:

  • The first time the patient reaches out to you for medical service
  • Before any submission of a home health request for anticipated payment (RAP)
  • Before any submission of a hospice notice of election (NOE)
  • Before every claim submission

What information do you need to check Medicare status?

To check Medicare eligibility, you must have the following patient information:

  • First and last name
  • Medicare Beneficiary Identification number (MBI)
  • Date of birth (month, day, 4-digit year)
  • Gender

What can you communicate to patients with a Medicare eligibility check?

Communicating often and effectively with patients is key to receiving complete payment for medical services in a timely manner. Being able to check Medicare status quickly and often will allow you to know and communicate to patients:

  • The deductible amount they have remaining for the year
  • Information about their primary insurance if Medicare is the secondary payer
  • Any patient-enrolled Managed Care Organization (MCO) or Health Maintenance Organization (HMO)
  • That status checking is 100% HIPAA compliant

Let ABILITY help with your Medicare eligibility checks

No matter the size your practice or healthcare organization, ABILITY can help simplify complex revenue cycle management processes with the latest data-driven applications. You can count on us to optimize reimbursements and the quality of care you offer. Request a demo of ABILITY CHOICE Medicare Eligibility today. We look forward to helping your organization grow!