WASHINGTON, D.C. (October 3, 2019)—The Centers for Medicare & Medicaid (CMS) announced that the next state to participate in the Review Choice Demonstration (RCD) is Texas and it will begin on Dec. 2, 2019. CMS also indicated that implementation of RCD in the remaining states of North Carolina and Florida is expected to begin on March 30, 2020, as CMS is pausing implementation to allow for the transition to PDGM which begins on Jan. 1, 2020.

The National Association for Home Care & Hospice (NAHC) believes CMS should consider postponing the RCD in Texas, as well, since the Patient-Driven Groupings Model (PDGM) begins just 30 days later. NAHC is glad to see a pause in implementation, as the association has advocated against RCD and PDGM beginning simultaneously, although we the organization hoped that CMS would consider evaluating RCD in Illinois and Ohio before expanding to any other state.

“We have long believed that there are much more effective and efficient claim oversight approaches available to Medicare rather than the burdensome RCD,” said NAHC President William A. Dombi, in reaction to the news. “The continuing reductions in “improper payment” rates is a validation of that view. However, the immediate focus is the timing of any expansion of RCD into Texas. We have asked CMS to postpone the planned start date to avoid adding the intense RCD-related workload to the essential changes that HHAs must make to properly transition to PDGM. The payment reforms are the most significant operational changes for HHAs in the last 20 years. The work needed with PDGM is ongoing and will be at its highest intensity in November and December. Texas HHAs need to be focused on PDGM not RCD paperwork.”

Medicare certified home health providers in Texas will have from Oct. 16, 2019–Nov. 14, 2019 to make their RCD choice selection via the Palmetto GBA eServices portal. Selections must be made through eServices so any Texas providers not already signed up for eServices should do so now using the eServices portal link. Texas HHAs that do not make an RCD choice selection by November 14 will be automatically placed in Choice 2: Postpayment Review.

HHAs will initially select between three review choices:

  • Choice 1: Pre-Claim Review,
  • Choice 2: Postpayment Review, or
  • Choice 3: Minimal review with a 25% payment reduction. (HHAs that select this choice will remain in this choice for the duration of the demonstration regardless of their claim approval rate).

HHAs that do not actively select one of the initial three review choices will be automatically assigned to participate in Choice 2: Postpayment Review. Palmetto is sending letters to Texas HHAs detailing this information.

Please note: If a provider has multiple NPIs but with one PTAN, each NPI is to make an RCD selection as each NPI has its own calculated rates.

HHAs who select either Choice 1 or Choice 2 will be evaluated for 6 months. If the HHA’s full affirmation rate or claim approval for those 6 months is 90 percent or greater (based on a minimum of 10 submitted pre-claim review requests or claims), the HHA may select one of the three subsequent review choices:

  • Choice 1: Pre-Claim Review,
  • Choice 4: Selective Postpayment Review, or
  • Choice 5: Spot Check Review.

HHA’s that do not actively choose one of the subsequent review options will automatically be assigned to participate in Choice 4: Selective Postpayment Review, and will remain there for the duration of the demonstration.

NAHC has created an RCD webpage for members that contain valuable information and links to helpful resources. CMS has published a RCD HH Operational Guide that all providers affected by RCD should review. There are also several other helpful resources for RCD available from Palmetto. They are located at the Palmetto GBA Home Health Review Choice Demonstration webpage.