NOA glitches: Working through RTPs, other issues

Not exactly a trouble-free transition, but Palmetto GBA is offering a work-around

Glitches were expected during this month’s transition to Medicare’s new Notice of Admission (NOA) for home health – and that’s exactly what the new admission requirement is delivering.

Numerous agencies were reporting NOAs being returned to providers last week, with mounting concern about the RTPs causing the NOA to count as a late submission for providers, received outside the 5-day NOA timeframe and therefore subject to penalties.

Late last week, Medicare administrative contractor Palmetto GBA responded with a work-around to re-enter NOAs impacted by an RTP with reason code 19960, with Condition Code 15 removed, for re-processing without affecting the received date.

Providers will need to request a late NOA exception on the corresponding claim if it was late due to this issue. In its instruction to providers, Palmetto said providers should enter “Late due to CC 15 release” in the remarks on the claim.

“We knew, realistically, that there were going to be issues this month with the NOA transition,” said SimiTree Principal Jess Stover, who oversees SimiTree’s tech-enabled outsourced billing, collections, and revenue cycle management services.

“And that is exactly what we are seeing happen. Problems range from NOAs being returned to providers to confusion about cross-over periods of care that began in 2021 and cross over into this year. There are some other issues as well,” Stover said.

“These types of regulatory transitions tend to be glitchy,” she added.

The NOA became effective on Jan. 1, 2022, when the Centers for Medicare and Medicaid Services (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.

One important 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. Stover said the penalty for failing to submit the NOA can be hefty.

“Agencies stand to lose payment for each day services are provided until the NOA is submitted and accepted by the MAC,” Stover said. “Previously, the maximum amount a forgotten RAP could cost an agency would be the entire 30-day payment period. Since the NOA is a one-time submission covering an entire episode instead of just one 30-day payment period, a forgotten NOA could actually cost an agency every 30-day period for an entire episode.”

A few tricky areas

Among the tricky areas for agencies during this month’s NOA transition are: 

  • A new one-time “artificial admission date” for periods of care spanning both 2021 and 2022. For periods of care crossing over 2021 into 2022, CMS wants agencies to create an artificial admission date which corresponds to the ‘from’ date of the first 30-day billing period in 2022. 
  • A requirement for both a RAP and a NOA to be completed for any crossover periods of care spanning both 2021 and 2022. “Remember that the RAP retirement date is based on dates of service,” cautions Stover. “Agencies will need to pay careful attention to this during the transition." 

Need help with billing?

As home health and hospice billing requirements for Medicare intensify, SimiTree has greatly expanded its billing, collections, and revenue cycle management services with the acquisition of Miami-based Imark Billing.

The acquisition positions SimiTree to handle increasing demand for outsourcing and quickly deploy resources to help agencies, she said.

“Our expanded resources enable us to work agencies of all sizes, from start up to enterprise,“ Stover said. “We offer full outsourcing solutions as well as consulting services to help with cash flow, compliance, claims processing delays, and profitability.”

Reach out to learn how SimiTree can help your agency, and get a free quote on our outsourced billing, coding, and full revenue cycle management services.

Call 800-949-0388 or fill out the Contact Us form below.

Learn more at our webinar

Learn more about the NOA and best practices for getting it right by joining us for a webinar Thursday, Jan. 27, at 11 a.m. Eastern. Register here.

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