Six months into the new Medicare Notice of Admissions (NOA) requirement, some Home Health Agencies (HHA) are still having trouble adapting to process changes. While the NOA submission process sounds simple enough (it only requires two pieces of information), adapting to a new routine typically doesn’t happen overnight. HHA’s need to be cautious of the new changes and stay organized – or it could end up affecting reimbursements.

The NOA requirement replaces the old Request for Anticipated Payment (RAP) system. Intended to inform CMS (Centers for Medicare & Medicaid Services) when a patient is on service and prevent overlapping admissions, it accomplishes three things:

1. Establishes the primary home health agency for a given time
2. Consolidated billing for agencies to help prevent double billing of services
3. Institutes more control for CMS

Although some of the new requirements mirror the RAP process, there are new protocols that some HHA’s are struggling to adjust to. New or old, we have identified some of the biggest hurdles that agencies need to focus on to keep operations efficient and prevent loss of revenue.

RAP: Required resubmission each 30-day period for however long a patient was under the agency’s care

NOA: Once for each new admission, regardless of how long they are in care (valid until the patient is discharged)                 

Best Practices:

• When a patient is discharged and then readmitted, a new NOA must be submitted
• Ensure discharge entries and transfer status records are recorded timely, to prevent denials for your agency or the patient’s new agency 
• Get in the habit of submitting a NOA even if Medicare is not the patient’s primary insurance

RAP: The 2020 RAP was due prior to the final claim submission. In 2021 this changed to within five calendar days from the start of care (SOC)/admission date, with the SOC date counted as day zero.

NOA: Within five calendar days from the admission date, with the SOC date counted as day zero (no change from the 2021 RAP)         

Best Practices:

• Check eligibility coverage before submitting
• File NOA’s as soon as a verbal or written order from the physician is obtained and the agency has completed the initial SOC visit
  • Within 24-48 hours from admission
• Verify the NOA is free of errors and has been accepted by the MAC (Medicare Administrative Contractors) – daily until the NOA has been accepted
• Establish a contingency plan to cover staff vacations or other shortages to keep submissions timely

3.  Harsher Penalties for Late Submissions

RAP: No-pay RAPs maximum cost was capped at a 30-day payment period

NOA: For each day the NOA is late, a payment reduction equal to 1/30^th of the full amount will be automatically deducted. If the NOA is still not submitted by the sixth day of admission, the penalty will increase to 6/30^th. If 30 days past due, the penalty will be applied to the initial period of care and the ongoing 30-day periods of care until the NOA has been accepted.                 

Best Practices:

• Remain diligent and ensure all proper documentation is presented within the five-day window
• Keep an external log to track NOA status daily until it is approved
• Utilize EMR tracking reports
• Understand proper use of placeholder and condition codes, and use as necessary to meet deadlines
• Educate your billing, intake, and clinical staff so they understand the importance of timely filing
• Notify agency leadership of penalties resulting from a late NOA

Need help hitting your goals? Contact our Home Health Consultants.

NOA penalty fees can really add up. If your agency needs help keeping them below 1%, contact the Revenue Cycle and Reimbursement Consulting team at Richter. Visit us online or call us at 866.806.0799.