Get Ready for Incoming Payment Policy Changes

The recent updates from the Centers for Medicare & Medicaid Services (CMS) for the Home Health Prospective Payment System (HHPPS) are meant to enhance payment programs and reduce the regulatory burden for home health agencies (HHAs). However, with an increase in claim forms and new filing policies, staying on top of these changes can be daunting.

Here’s how the updates will impact agencies and how they can ensure timely reimbursements and streamlined workflows.

Changes to RAPs

Per the new updates to the HHPPS, starting in 2020, HHAs received a 20% upfront payment when filing request for anticipated payment (RAP) claims, a reduction from 50% to 60% up front in previous years. Additionally, HHAs transitioned to filing RAPs every 30 days in 2020, as the implementation of the Patient Driven Groupings Model changed billing from one 60-day episode to two 30-day payment periods within a 60-day episode of care.

As of January 2021, upfront payment has now been eliminated. On top of this, home health agencies need to submit the no-pay RAP within five calendar days of each 30-day period or be subject to a penalty, increasing the resources needed for filing claims on time. The purpose of the no-pay RAP is to alert the claims processing system that a Medicare beneficiary is under a home health period of care. In 2022, RAPs will be eliminated and HHAs will only have to complete a one-time submission of a notice of admission (NOA) per beneficiary within five calendar days. From the dramatic increase in claim forms to tightened deadlines, HHAs have a lot of adjustments to make in just two years.

Navigating the Changes Ahead

Now that HHAs will have to submit twice as much paperwork in just under a week, administrators need to prioritize the timely submission of claims to avoid penalties and maximize reimbursement, especially since the five-day deadline includes weekends. Under the new HHPPS policies, CMS will reduce payment by one-thirtieth each day until the RAP (and the NOA in 2022) is received, including the five-day period given for submission. For low utilization payment adjustment (LUPA) periods, the change will reduce the payment for each visit until the RAP submission date.

With the flurry of new paperwork and claims to file, here are some tips for agency administrators to ensure they have the appropriate resources needed to tackle these process changes.

1. Capture all necessary information during the intake process.

The last thing you want to happen when tackling a mountain of claims is to realize you’re missing information. Make sure that you have all the details you need from patients before sitting down to file. The right electronic health record (EHR) software can make that process easier by prompting the person inputting information for specific details during intake, such as insurance verification, primary diagnosis, name of physician and start-of-care date. The software can also review new referrals for overlapping home health episodes and notify billing. This will reduce your return provider claims where a Condition Code 47 is required.

When verifying insurance, it is important for agencies to keep backup documentation of eligibility. If the CMS common working file is not updated in a timely fashion, there is a potential that RAP claims could be returned and ultimately filed late. Backup documentation and proof of patient eligibility at the start of care will help appeal a late RAP submission penalty.

2. Create a schedule for filing claims.

Five days is not a long period of time to collect the necessary information and file claims for payment. With four claims within a 60-day period required for each patient, HHAs should designate resources to submit claims on a daily basis for all payers. The five-day window for claims submission also includes weekends, so it is important to review RAP claims on Fridays and submit them if the deadline is over the weekend.

One tip is to create a weekly collections plan, ranking your claims by filing days and accounts receivable balance. This plan can also be used to review and identify payer-specific trends that require attention. A good EHR can expedite the process to auto-release RAPs the moment that minimum requirements for submission are met.

3. Work with EHR providers to automate processes.

The right technology can help streamline workflows and give agencies more time to focus on high-level strategizing and patient care. Look for an EHR that can simplify processes like patient intake, automatically checking insurance eligibility, transmitting claims and checking claim responses directly with CMS.

With the introduction of NOA in 2022, home health agencies must acclimate to yet another new process. It is very similar to the notice of election for hospice programs, so agencies that service both will have processes in place already. You can also work with your team to collect feedback on what features your staff are looking for and ensure that your EHR is equipped to meet those needs. It would also be a good idea to reach out to your EHR vendor and see if there are any pilot programs for NOA you can participate in.

With lowered admission rates in 2020 due to the pandemic, home health agencies might not have felt changes from the HHPPS on their revenue cycle management. But with the continued vaccine rollouts and return of patient intake in the post-acute sector, administrators can expect an increased workload and new territory in the claim systems. Now is the time to initiate a plan of action—from allocating resources to using the right technology—to successfully tackle the rest of this year and prepare for 2022.