Courtesy of the National Association for Home Care & Hospice (NAHC)

The Centers for Medicare & Medicaid Services (CMS) has issued Change Request (CR) 12595 to update various sections within Chapter 4 of the Medicare Program Integrity Manual, including the removal of references to Request for Anticipated Payment (RAP) suppressions.

The CR also adds program integrity policies around abuses with the Notice of Admission (NOA).

CMS notes that the Medicare Administrative Contractors (MACs) may identify instances where a home health agency's use of NOAs indicates potential fraud, waste, or abuse. Upon identifying misuse of NOAs, the Medicare Administrative Contractors (MACs) are to initiate corrective action. Corrective action includes, but is not limited to, education, warnings, Corrective Action Plans, and referrals to the Unified Program Integrity Contractor (UPIC).

For misuses that are not significant enough to warrant immediate implementation of a Corrective Action Plan (CAP), the MAC may provide additional education and monitoring. If the NOA abuse warrants a CAP, the policy manual outlines the process for notifying the home health agency along with the process for the CAP submission, acceptance, and monitoring.

A MAC may determine that an agency's misuse of NOAs and/or other conduct warrants immediate referral to the appropriate UPIC.

CMS is not clear regarding what NOA misuses entail or the benefits for the agency conducting the abusive practice and impact to the Medicare program. Unlike the RAP, the NOA does not generate payments to the agency's directly associated with its submission.