In an earlier blog, we briefly touched on the challenges for the home health industry this year and the news just keeps getting – er – worse. For those who may not know, the Request for Anticipated Payment (RAP), which was phasing out in 2020, will be fully retired in 2021. Kind of. CMS will still require the submission of a RAP for no pay and penalize agencies for filing it late.
The RAP served a few purposes for agencies. By making a split percentage payment for new admissions, agencies could even out their cash flow and also establish themselves as the beneficiary’s primary HHA with CMS. This allowed CMS to reject claims from other providers for the duration of the episode. Agencies then filed a final claim at the end of the episode, which triggered the balance of the payment.
However, because CMS changed the episode of care to 30 days, it changed the RAP to a zero payment. Agencies are still required to submit a RAP at the beginning of each 30-day period when 1) the written clinician order that sets out the services for the initial visit has been received and 2) the initial visit has been made and the beneficiary has been admitted to the agency. This must occur within five days of the start of care. If the agency does not file the RAP, there will be a “non-timely submission payment reduction” for every day the RAP is late.
CMS provides for a small number of exceptions to the non-timely RAP submission but they are not regularly occurring circumstances. Coleman Consulting Group does not handle home health billing but we’re fortunate to refer clients to our colleague, Imark Billing. Here is YouTube video they posted on this subject. Lynn and her team focus exclusively on home health and hospice billing and can help your agency avoid unnecessary payment reductions, especially at this crucial time.