Palmetto GBA plans to suppress RAP payment to home health agencies with a large number of auto-cancelled RAPs. Here is an excerpt from their most recent communique:
“Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim. If the final claim is not submitted with the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim. It is expected that instances where the RAP is auto-cancelled for no submission of a final claim should be minimal.
Palmetto GBA is monitoring the number of RAPs that are auto-cancelled due to providers not filing a final claim. In accordance with Medicare regulations, contractors have the authority to revoke a provider’s privilege to receive payment on the RAP. Therefore, providers identified with a high number of RAP auto-cancels due to no final claim will be notified that their RAPs will be set to pay at zero percent. The payment suppression will continue until a Corrective Action Plan is submitted and the provider can demonstrate improvement in timely billing of final claims. We will not be withholding the RAP payment; we will simply not pay RAPs for these aberrant providers. The affected providers will only be paid for final claims.
Other providers that are identified to have RAPs auto-cancelled for no final claims that are below the acceptable threshold will be notified that their current billing practices are unacceptable and their RAPs are being monitored. If improvement is not noted within a reasonable amount of time, future RAPs may be set to pay at zero percent.”
Details are slowly emergining, but here is what we know thus far:
- RAP payments are being suspended for 298 home health agencies because they failed to submit final claims for 100 or more RAPs between January and April. The agencies’ performance will be monitored and RAP payments restored if improvement occurs. The targeted agencies had 100 or more RAPs auto-cancelled with some as high as 1300-4000.
- Palmetto is the only MAC suppressing RAP payments at this time. However, all MACs have the authority to do so.
Providers who wind up having their RAPs suppressed have an opportunity to exit RAP suppression if they show sufficient improvement in the number of RAP’s that are auto-cancelled.
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