CMS Updates No-Pay RAP Guidance

WASHINGTON, D.C. (November 6, 2020)—The Centers for Medicare & Medicaid Services (CMS) has issued another revision to change request 11855—Penalty for Delayed Request for Anticipated Payment (RAP) Submission—Implementation. The Change Request (CR) revision added remittance advice message information related to the No Pay RAP penalty.

Home health agencies (HHAs) should note that Medicare Administrative Contractors (MACs) will: 

• Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (loop 2100) on Home Health Claims on the 835 ERA o Group Code: CO o Claim Adjustment Reason Code (CARC): 95 (“Plan procedures not followed”) 
• Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (Loop 2320) on Home Health Claims to the 837I COB o Group Code: CO o CARC: 95 (“Plan procedures not followed”) that and CMS added that information to the article. CMS also changed the CR release.

The CMS No Pay RAP policy, effective Jan, 1, 2021, will require home heath agencies to submit the RAP within five days of the from date for each claim or a penalty will be applied to the final claim that equals 1/30 of the 30 day period claim amount for each day the RAP is late. Although CMS has relaxed the criteria for the submitting the RAP beginning in 2021, HHAs are concerned with their ability to comply with the No Pay RAP requirements and the submission time frame.

The National Association for Home Care & Hospice has developed a No Pay RAP Fact Sheet and Frequently Asked Questions document that should help HHAs prepare for the No Pay RAP requirements.