Courtesy of the National Association for Home Care & Hospice

Effective September 1, 2021, home health providers in Florida and North Carolina will see full implementation of the Review Choice Demonstration (RCD).

The RCD was originally scheduled to begin in the two states on May 4, 2020, but was delayed by the COVID-19 Public Health Emergency. Instead, a phased-in approach began in August 2020 allowing providers in these states to voluntarily participate. This phased-in approach was extended several times, most recently in June until July 31, 2021.

Florida and North Carolina will have an additional mid-cycle selection period, as detailed below:

• Selection Period Start Date: August 1, 2021
• Selection Period End Date: August 15, 2021
• New Selection Effective Date: September 1, 2021

Providers who made a selection during the first selection period for Cycle 2 in April and wish to remain in the same option they previously selected do not need to take any action.

Providers who previously made a selection for Cycle 2 in April and wish to change their selection will have the ability to do so during the mid-cycle selection period. The RCD choices available to these providers will be based on their Cycle 1 results.

Providers who did not previously make a selection for Cycle 2 and do not make a selection during this mid-cycle selection period will default to either Choice 2 (Post-payment Review) or Choice 4 (Selective Post-payment Review) based on their Cycle 1 results.

Cycle 2 for Florida and North Carolina will end on October 31, 2021.

The Centers for Medicare & Medicaid Services (CMS) will resume applying the 25 percent payment reduction where applicable in Illinois, Ohio, and Texas.

For Florida and North Carolina home health agencies, claims with dates of service on or after August 31, 2020, submitted on or after September 1, 2021, without a pre-claim review decision on file will be pulled for pre-payment review, but will not be subject to the 25% reduction during that period for 90 days. This was announced during the Palmetto GBA Home Health Review Choice Demonstration webinar held on August 4, 2021, in response to ongoing outreach by the National Association for Home Care & Hospice (NAHC), HCAF, and the Association for Home & Hospice Care of North Carolina. A recording of the August 4 webinar can be accessed here.

Palmetto GBA, the Medicare Administrative Contractor (MAC) administering the RCD, has stated that effective September 1, 2021, all billing periods will be subject to the requirements of the review choice selected. This will include any billing periods that have 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).

• Related: CMS Announces Mid-Cycle Selection Period for Florida and North Carolina Home Health Providers (July 30, 2021)