Home Health: From RAP to NOA

The changes to home care continue and all of us in healthcare are certainly accustomed to the alphabet soup of our industry.  Here’s a new one:  NOA, or Notice of Admission.  If you’ve been in home care a while, you recall submitting RAPs or Requests for Anticipated Payment; these were down payments – if you will – or advances against the total claim for a home care certification period.  In 2021 we saw the complete phasing out of the RAP and the requirement to submit a No-Pay RAP to alert CMS of a new certification period.

Effective January 1, 2022, CMS will now require a one-time Notice of Admission (NOA) which accomplishes the same goal: notification.  To submit the NOA, you need a verbal or written physician order and you must have conducted the initial visit at the start of care. The NOA is valid for all contiguous 30-day periods of care, from admission to discharge, so the agency need only submit it one time.  Once you discharge a patient to Medicare, agencies will need to send a new NOA before submitting additional claims for payment.

If the beneficiary is receiving home health services in 2021 and those services will continue into 2022, agencies will submit a one-time NOA using an “artificial admission” date.  This date, listed under “from,” will be the date of the first period of continuing care in 2022.

As expected, CMS will apply a non-timely submission penalty for late NOAs if they’re not submitted within five calendar days of the start of care.  Read the CMS bulletin for more useful information.

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