Almost eight months into Medicare’s requirement for a new Notice of Admission (NOA) for home health patients, the Centers for Medicare and Medicaid Services (CMS) continues to sort out associated glitches.
The most recent “fix” occurred July 21, when CMS issued a new hospice Change Request to ensure prior periods of care are updated correctly when an NOA is canceled, and medical review information is not removed when claims are subsequently adjusted.
“This modification was needed to address problems which were causing some unnecessary extra administrative work for agencies,” said Lynn Labarta, SimiTree Vice President, Post-Acute Revenue Cycle Management.
“We were seeing problems in transfer situations when home health agencies had to cancel and resubmit their NOAs before any of their claims could be processed,” Labarta said.
“And we were seeing some instances where medical review coding on the claim was accidentally erased when the claim was adjusted, triggering a request for additional record review to providers in those cases,” she said.
What CR 12790 does
Change Request (CR) 12790 ensures prior periods of care are updated correctly when an NOA is canceled. It also ensures medical review information is not removed when claims are subsequently adjusted due to period sequence edits.
NOAs are submitted using Type of Bill (TOB) 032A and may be canceled with TOB 032D if they are submitted in error, Labarta said. However, a glitch in the system did not account for reversing changes to the previous admission period when the NOA was received in a transfer situation, she said.
Under some circumstances, when a transfer NOA was submitted in error and subsequently canceled, the TOB 032D removed the transfer home health agency’s admission period but did not restore the original calculated 30-day End date on the period of the previous HHA.
“This meant the previous home health agency had to cancel and resubmit the NOA before any of the claims could be processed,” Labarta said.
The change request also corrects an issue with claims which have been medically reviewed and identified for adjustment due to an incorrect period sequence.
Medicare systems were changing the User Action Code from the code applied by the medical review, and accidentally erasing medical review coding on the claim.
“For providers still on review, this has been triggering an unnecessary additional record request to the provider. If the provider is no longer being reviewed, the claim continues processing without the medical review coding, which impacts medical review reporting,” Labarta said.
The July 21 hospice change request corrects both issues.
An ongoing adjustment
The latest hospice change request comes on the heels of a long and ongoing adjustment period for NOA, which became effective Jan. 1, 2022, when CMS replaced its no-pay Request for Anticipated Payment (RAP) with the new admission requirement.
Like the RAP, the NOA must be completed within five calendar days from the start of care date – but unlike the RAP, it is a one-time submission covering contiguous 30-day billing periods until the patient is discharged from home health services. Previously, home health providers were required to submit a new no-pay RAP for each 30-day payment period.
Another significant difference between the RAP and the NOA is in the amount of the penalty which can be levied for failure to meet the submission timeframe. Agencies lose payment for each day services are provided until the NOA is submitted and accepted by the MAC. Previously, home health providers were required to submit a new no-pay RAP for each 30-day payment period.
Need help with RCM?
Ongoing glitches with the NOA illustrate just one of many ways the billing process for home health is becoming increasingly complex and time consuming, Labarta said.
Audits are increasing as well. SimiTree compliance experts say they are receiving more requests for assistance with audits, and caution agencies that more payment-related audits are expected in response to a recent call by the Office of Inspector General (OIG) for heightened scrutiny.
“This means more scrutiny from Recovery Audit Contractors (RACs) and other Medicare contractors, as well as more Targeted Probe and Educate (TPE) audits,” Labarta said.
SimiTree offers full revenue cycle management services to ease the burden on agencies by increasing cash flow, insulating agencies against billing errors that lead to audits, and providing the regulatory knowledge to keep up with constant change.
“Our expanded resources enable us to work agencies of all sizes, from start up to enterprise,” Labarta said. “We offer full outsourcing solutions as well as consulting services to help with cash flow, compliance, claims processing delays, and profitability.”
Use the form below to reach out to us today and learn how SimiTree can help your agency with outsourced billing, coding, or full revenue cycle management services.