NOA and Crossover Periods of Care: It’s Complicated

Glad to see the no-pay RAP gone, replaced by a new Notice of Admission (NOA)? Looking forward to filing the NOA only once between start of care and discharge instead of every 30 days?

Not so fast.

Your agency may not be through with the no-pay RAP just yet, even though the Centers for Medicare and Medicaid Services (CMS) has retired the RAP (Request for Anticipated Payment) in 2022.

“Remember that the RAP retirement date is based on dates of service,” cautions SimiTree Principal Jess Stover, who oversees SimiTree’s outsourced billing, collections, and revenue cycle management services.

Your agency could be incurring daily penalties for failing to comply with the requirement to file a RAP for every 30-day payment period that began on or before Dec. 31, 2021. If the period of care began in 2021 – even in the waning hours of New Year’s Eve as the clock ticked toward midnight – a no-pay RAP will be required to get paid.

“This means penalties could continue to affect payment from late RAPs,” Stover said. “Agencies need to pay careful attention to this during the transition.”

Crossover periods of care spanning both 2021 and 2022 will also require a NOA, and here’s where it gets a little complicated. CMS wants agencies to fudge a little, on the admission date, just this once, for the first 30-day period of care in 2022.

New artificial admission date

Medicare has introduced a new term, the “artificial admission date,” for periods of care spanning both 2021 and 2022.

“CMS wants agencies to use the new, one-time artificial admission date for these crossover periods of care,” Stover said. “The first day of the first 30-day period of care in 2022 will be the artificial admission date. It will correspond to the ‘From’ date of the first 30-day payment period in 2022.”

Some EMRs may not be able to accommodate the one-time artificial admission date for the limited number of crossover periods of care, Stover said, so agencies will have to manually key in the information for crossover periods of care.

“These types of regulatory transitions tend to be glitchy,” Stover said. “This one is a great example of how it can be challenging for agencies. Manually keying in the artificial admission date requires extra work for agencies, and the process for manually keying it in is slightly different from electronic submission, so it can quickly get confusing.”

Stover recommends agencies refer to a step-by-step guide put together in a collaborative effort between Medicare administrative contractors CGS and Palmetto GBA. The guide may be downloaded here.

More NOA compliance tips

Stover offered a few additional compliance tips for the transition to NOA: 

  • Make certain to cancel any RAPs already filed for periods of care beginning in 2022. Because agencies were allowed to file no-pay RAPs for subsequent periods of care in advance, many agencies developed a routine of filing RAPs for subsequent periods at start of care. Only periods beginning in 2021 will need a RAP. 
  • Have in place a follow-up procedure to make certain the MAC has accepted the NOA after submission, so that appropriate action can be taken quickly when needed to meet the five-day timeframe. 
  • Remember that the requirements for filing the NOA are the same as for the no-pay RAP. Agencies have five days from start of care to submit the NOA. Start of care counts as Day 0. A verbal or written order from the physician will be required, and it must specify home health services required for the initial visit. Agencies must also have conducted the initial, billable visit. The OASIS does not have to be locked prior to submitting the NOA.

SimiTree can help

At SimiTree, we understand that it can be confusing and time-consuming to stay on top of constantly changing regulatory requirements – and costly when you make a mistake. We’re here to help, so that you can focus on your patients. We’ll provide all the training your staff needs for full compliance, or we’ll handle all the work for you with our full array of outsourced billing, collections, cash posting and revenue cycle management services. Contact us today.

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