Courtesy of the National Association for Home Care & Hospice

In an August 26 announcement, the Centers for Medicare & Medicaid Services (CMS) announced it is modifying the Review Choice Demonstration (RCD) in Florida and North Carolina so that only those claims with dates of service beginning on and after September 1, 2021, will be subject to Additional Documentation Request (ADR)/pre-payment review if they are submitted without a Unique Tracking Number (UTN)/pre-claim review decision.

After CMS announced earlier this month that effective September 1, 2021, full implementation of RCD would begin for home health providers in Florida and North Carolina, the National Association for Home Care & Hospice (NAHC) raised concerns about the policy with the agency and began advocating for CMS to revise their implementation plans to alleviate these concerns.

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Specifically, as part of the full implementation, claims with dates of service on or after August 31, 2020, that are submitted on or after September 1, 2021, without a pre-claim review decision on file were to be pulled for pre-payment review and subject to the 25% reduction.

Following outreach by NAHC, the Home Care Association of Florida, and the Association for Home & Hospice Care of North Carolina, CMS announced that the 25% reduction would not be applied for a period of 90 days from the full implementation date of RCD in Florida and North Carolina. Access a recording of the August 4 webinar during which this was announced by clicking here.

However, NAHC remained concerned because all billing periods would still be subject to the requirements of the review choice selected. This would include any billing periods that had not yet been submitted as of September 1, 2021, with a date of service on or after the start of the demonstration in Florida and North Carolina (August 31, 2020).

Therefore, NAHC went back to CMS because the pressures of the COVID-19 public health emergency that led to the phased-in implementation and transition policy have not eased. In fact, in some places, the COVID-related pressure has, if anything increased. To require agencies that wish to use pre-claim review to submit both the claims that involve starts of billing periods before September 1 along with those that start September 1 and later more than doubles the workload in the near term. If agencies try to space out those two claims groups to mitigate the workload concerns, cash flow problems could be triggered. Also, providers have had the understanding, based on communication at the onset of the phased-in implementation of RCD in Florida and North Carolina, that the transition would not implicate services that were started before the trigger date of full RCD.