RAP vs. NOA: The 3 Big Changes

Here’s a refresher on what’s changing under the new admission requirement

Home health agencies are bracing for potential cash flow shortages, confusion about periods of care that began in 2021 and cross over into this year, and other potential issues related to the implementation of Medicare’s new Notice of Admission (NOA).

The Centers for Medicare and Medicaid Services (CMS) replaced its no-pay Request for Anticipated Payment (RAP) with the NOA on Jan. 1, 2022.

“2021’s transition to the no-pay RAP was a rocky one for many agencies,” said SimiTree Principal Jess Stover, who oversees SimiTree’s outsourced billing, collections, and revenue cycle management services. “We’re hoping agencies will have an easier time of it this year, with the NOA, since many of the NOA requirements are the same as they were under no-pay RAPs.

“But there are a few tricky areas, including some new Medicare terminology and a new procedure for handling payment periods for care that cross over from the old year into the new,” Stover said.

Here’s a look at the three most significant changes under the NOA.

One-time submission

One of the biggest differences between the no-pay RAP and the NOA is the submission frequency.

Previously, agencies were required to submit no-pay RAPs for each 30-day payment period. The NOA is a one-time submission covering contiguous 30-day billing periods until the patient is discharged from home health services. A new NOA will be required to submit any additional claims once a discharge has been reported to Medicare.

Heftier penalties possible

Like the RAP, the new NOA must be submitted to an agency’s Medicare administrative contractor within five calendar days from the start of care date – and Stover warns that the penalty for failing to meet the NOA timeframe could be significantly higher than agencies saw under the no-pay RAP.

“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.”

New artificial admission date required

Medicare has introduced a new one-time procedure and a new term to handle periods of care spanning both 2021 and 2022.

“CMS is asking agencies to create an artificial admission date – a new term agencies need to become familiar with fast – corresponding to the ‘from’ date of the first 30-day billing period in 2022,” Stover said. “The NOA date for any 30-day periods of care crossing over 2021 into 2022 will be the first day of the first 30-day period of care in the new year.”

As an example, she said, for a 30-day billing period which began 12-13-2021 and ends 1-11-2022, an artificial admission date of 1-12-2022 will be used for the NOA.

“This is going to be confusing for many agencies in January,” Stover said. “It’s going to make extra billing work for agencies, and we’re expecting to get a lot of calls for help. There may also be some confusion on the part of the MACs, with errors on their part, very similar to what we saw last year with the new RAP requirements.”

A look at what’s staying the same

Some requirements currently in place for submitting the RAP will remain the same under the NOA.

  • 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 have conducted the initial, billable visit at the start of care. 
  • The NOA must be submitted within 5 days from the start of care to avoid penalties.

Although agencies have 5 days to submit the NOA, Stover said SimiTree recommends agencies follow best practices and try to submit within 24-48 hours. “Remember that it isn’t necessary to wait on the OASIS to be completed,” she said.

Stover also recommends agencies 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.

Full NOA details are provided in the revised Chapter 10 of the Medicare Claims Processing Manual.

Need help with billing?

As home health and hospice billing requirements for Medicare intensify, SimiTree is expanding its billing, collections and revenue cycle management services in 2022 to handle increasing demand for outsourcing.

“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 form below.

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