For owners of home health agencies, 2020 has been a year defined by changes and challenges on multiple fronts. Certainly, the coronavirus (COVID-19) pandemic has caused financial and operational disruptions. But agencies also must navigate important changes around requests for anticipated payment (RAPs). Failure to adequately prepare could put agencies – particularly small and midsize ones – in dire financial jeopardy.
So, how can your agency address this challenge? It starts by understanding the changes themselves.
Request for Anticipated Payment (RAP) Changes – What They Mean for Home Health Agencies
In January 2020, CMS reduced RAP payments to 20%, which represents a 30-40% reduction. Additionally, home health agencies certified on or after Jan. 1, 2019 must submit RAPs every 30 days—yet they will receive no RAP payment, and the split percentage will be zero. Agencies certified before Jan. 1, 2019 can continue to submit RAPs and will receive a split percentage payment.
What’s the change? In 2021, RAPs will still be used to establish the beneficiary’s home health agency on the common working file (CWF). All agencies will no longer receive payment, regardless of when the agency became certified. In addition, agencies will be penalized if RAPs are not submitted within a five-day time period.
The information below, summarized from the Medicare Learning Network 11855, explains this in detail:
“The RAP serves a greater operational role for the Medicare program by establishing the beneficiary's primary HHA in the Common Working File (CWF), so that the claims processing system can reject claims from providers or suppliers, other than the primary HHA, for the services and items subject to consolidated billing.
Starting in calendar year (CY) 2021, the split-percentage payment will be lowered to 0 percent for all HHAs (newly enrolled and existing).
Therefore, submit a RAP when:
The appropriate physician’s written or verbal order that sets out the services required for the initial visit has been received and documented as required at 42 Code of Federal Regulations (CFR) Sections 484.60(b) and 409.43(d)
The initial visit within the 60-day certification period has been made and the individual is admitted to HH care (84 FR 60548)
Also for CY 2021, there will be a non-timely submission payment reduction when the HHA does not submit the RAP within five calendar days from the start of care date (“admission date” and “from date” on the claim will match the start of care date) for the first 30-day period of care in a 60-day certification period and within five calendar days of the “from date” for the second 30-day period of care in the 60-day certification period.
This reduction in payment will be equal to a 1/30th reduction to the wage and case-mix adjusted 30-day period payment amount for each day from the HH (home health) start of care date/admission date, or “from date” for subsequent 30-day periods, until the date the HHA (home health agency) submits the RAP. The 1/30th reduction would be to the 30-day period payment amount, including any outlier payment, that the HHA otherwise would have received absent any reduction.
For LUPA 30-day periods of care in which an HHA fails to submit a timely RAP, no LUPA per-visit payments will be made for visits that occurred on days that fall within the period of care prior to the submission of the RAP.
The payment reduction cannot exceed the total payment of the claim. The payment reduction for the late submission of a RAP can be waived for exceptional circumstances as outlined in regulations at 42 CFR 484.205(i)(3).”
RAPs Changes Underscore the Need for Process Review and Improvement
You’ve hopefully already prepared for these RAP changes. If you haven’t yet, the time to start is now—and the place to start is with a thorough review of your processes and procedures.
Having optimal processes and procedures in place benefits your home health agency in significant ways, including:
Facilitating your efforts to get RAPs out within the five-day window to avoid being penalized additional money
Streamlining the process of getting final claims out timely
Helping to ensure you are fiscally responsible in all facets of your operation
Too often, our Home Health Performance Advisors find this is easier said than done for many agencies. In the past, one of the biggest holdups we saw with many agencies in getting RAPs out timely was not the order, but rather, completing initial Oasis assessment in a timely manner. Additionally, if you subcontract out coding, that could be an issue as well, because it takes longer to send the claims out, get them coded and then bring them back. With the new rules, the Oasis does not need to be completed prior to submitting your RAPs. You are allowed to use the generic HIPPS code, which we at Richter recommend. If you are subcontracting out the coding, then utilize the diagnosis code that was given to you at the time of referral.
Additional delays in getting your RAP out within five days can occur when nurses and therapy staff don’t submit their notes timely. In this regard, it’s key for clinical staff to submit their documentation within 24 hours.
Again, the services your home health agency provides are vital to the health and well-being of patients. Yet, to continue delivering services, you must remain financially and operationally viable, today and tomorrow. By having the right processes and procedures in place to ensure timely RAP and final claims filing, you’ll be taking a big step in the right direction.
Contact Richter Home Health Consultants
Do you have questions about RAPs changes, optimizing processes and procedures around billing, navigating your home health or hospice agency through the COVID-19 crisis, or other home health and hospice clinical challenges? Call Richter’s home health consultants at 866-806-0799 to schedule a free consultation.