05.17.2024

CMS Extends The Home Health Review Choice Demonstration (RCD) for 5 Years with Important Updates

The wait is now over! As many home health agencies anticipated, the Centers for Medicare & Medicaid Services (CMS) have finally announced the future of the Review Choice Demonstration (RCD) program for Home Health Agencies (HHAs).

Here's a breakdown of the key takeaways from the experts at SimiTree and what it means for you:

The Good News: RCD Extended!

The RCD program has been a game-changer for HHAs. Launched to streamline Medicare claim reviews and reduce administrative burdens, the program offers HHAs more control over how their claims are reviewed. Traditionally, Medicare would review claims after services were provided (postpayment review), which could lead to delays in reimbursement and create uncertainty for HHAs. The RCD program introduced alternative options, including pre-claim review, where HHAs can submit claims for review upfront before services are rendered. This allows HHAs to identify any potential issues early on and avoid claim denials later. Additionally, the program offered a minimal review option with a reduced payment, providing some flexibility for HHAs comfortable with a lower level of scrutiny.

That’s why the latest update on the future of RCD, Effective June 1st, 2024, HAS HHAs in Illinois, Ohio, Texas, North Carolina, Florida, and Oklahoma, breathing a collective sigh of relief. The RCD program is officially extended for an additional 5 years! This means HHAs can continue to benefit from the program's ability to streamline Medicare claim reviews, potentially reducing administrative burdens. By offering pre-claim review as an option, HHAs can gain valuable upfront clarity on whether their claims will be approved, avoiding the stress and financial strain of claim denials later. This predictability can also help HHAs focus on providing high-quality care to their patients, knowing they'll be reimbursed for approved services.

Important RCD Update: New Changes to Choice Options

CMS is removing Choice 3, the option known as "Minimal Review with 25% Payment Reduction." This simplifies the initial choices for HHAs, leaving Pre-Claim Review and Postpayment Review as the two primary options. Current Choice 3 providers must select between the other two initial review choice options: Pre-Claim Review or Postpayment Review, according to the following dates:

  • Choice selection period start date: June 17, 2024
  • Choice selection period end date: July 1, 2024
  • Cycle effective date: July 15, 2024

Here's a quick breakdown of what this means for HHAs:

  • Pre-Claim Review: Under this option, HHAs submit claims electronically to a Medicare contractor for review before services are provided. The contractor reviews the claim for accuracy and medical necessity, and if approved, the HHA receives written confirmation that the claim is likely to be reimbursed. This upfront review process can help HHAs identify and address any potential issues early on, significantly reducing the risk of claim denials later. While pre-claim review offers greater certainty, it can add an extra step to the claim’s submission process.
  • Postpayment Review: For those that do not make an initial selection, this will be the default choice. Postpayment Review is also the traditional method of Medicare claim review, where claims are submitted after services are rendered. The contractor then reviews the claim for accuracy and medical necessity. If the claim is approved, the HHA receives full reimbursement. However, if the claim is denied, the HHA may face delays in receiving payment and may have to appeal the decision. While postpayment review avoids any upfront steps, it carries the risk of claim denials and potential cash flow disruptions.

Action Required for Some Providers

If your HHA was previously enrolled in Choice 3 (Minimal Review with 25% Payment Reduction), don't worry! Palmetto GBA, the administrator overseeing the RCD program, will be reaching out to you directly.  They will be assisting you with selecting a new option – either Pre-Claim Review or Postpayment Review – by July 1st, 2024. Be sure to keep an eye out for their communication, which will likely arrive via email or phone call.  In the meantime, you can also proactively reach out to Palmetto GBA for any questions you may have regarding the transition process or your new choice options.

All other Home Health providers in the demonstration states will continue in their current review cycles and follow their regular cycle timelines. For Oklahoma providers, the choice selection period for cycle 2 is July 1, 2024, through July 15, 2024. Cycle 2 will begin on August 1, 2024. 

The Bottom Line

The RCD program's extension provides HHAs with continued flexibility in how Medicare reviews their claims. This can potentially reduce administrative burden and streamline the process, but it's important to understand the different options available (Pre-Claim Review vs. Postpayment Review) to make the best choice for your agency. Any providers who feel it is a hardship to continue participation in their current review choice selection and would like to modify their choice selection should notify Palmetto by June 14, 2024, to ensure their desired choice selection is updated.

Stay Informed and Get Help

Understanding the intricacies of the RCD program is crucial for HHAs. That’s why SimiTree experts are always available to help agencies answer pressing questions and provide services that make your organization healthier overall.

Not sure what is best for your agency? Schedule a one-on-one consultation today.

With a comprehensive team of experts like SimiTree, your team can be assured that all services are covered, including:

  • Full pre-claim submission
  • Operational assessment to identify compliance issues.
  • Corrective plan with staff training.
  • Consulting for selection cycle determination.
  • ADR and appeals management.

SimiTree RCD experts put all the experience gleaned in thousands upon thousands of pre-claim submissions and affirmations to work to your benefit. Costly agency resources and manpower requirements are eliminated, and providers receive assistance in catching up on RCD backlogs. SimiTree also helps assess, identify, and correct compliance issues through training and operational changes.

The SimiTree difference?

  • Expert and meticulous medical record review
  • Fast-tracking for claim submission
  • Consistently high affirmation rates
  • Feedback and guidance for improved compliance

Free up your staff to focus on what is important—taking care of your patients. We work seamlessly in the background, so there is virtually no need for your agency's daily involvement.

Learn more about how SimiTree can help your agency and request a phone call today. You can also visit CMS.gov. 

Contact Us

Let's work together to improve the health of your organization. At SimiTree, we balance financial expertise and clinical excellence to help our clients grow. How can we help you? Call us at 866.839.5471 or complete the form below.