Here are some home health related updates for this week:
SPECIAL NEW CLIENT OFFER FOR THE MONTH OF OCTOBER (TODAY IS THE LAST DAY!): If you subscribe to both, Skill Competency Program and Ongoing Training/Continued Education Management Program, you will receive 50% discount off the skilled competencies competed in the month of October.
Don’t forget, Ongoing Training/Continued Education Management Program is only $3.00 per user per month!!!)
The next available CNA/HHA and Skilled Nursing Competency is Tuesday, November 3rd, 2020 and Thursday, November 5th, 2020.
If you would like to register your Skilled Nurses and/or HHAs/CNAs for a competency, please follow the links below:
Skilled Nursing Competency: https://amityhealthcaregroup.com/services/nursing-competencies/
HHA/CNA Competency: https://amityhealthcaregroup.com/services/cna-hha-competency/
Let Amity Healthcare Group to assist you with staying compliant with competency and ongoing training/continued education requirements in a worry-free manner.
For more information, please call 303-690-2749 or email: firstname.lastname@example.org or schedule a meeting at https://calendly.com/ig–3/30-min-free-consultation.
Provider Relief Fund
Please remember that Applications for the Phase 3 Provider Relief Fund General Distribution are being accepted until 11:59 pm EST on November 6, 2020.
In addition, on October 22, 2020 U.S. Department of Health and Human Services (HHS) announced an update to its most recent Provider Relief Fund (PRF) reporting instructions to broaden use of provider relief funds. HHS is amending the reporting instructions to increase flexibility around how providers can apply PRF money toward lost revenues attributable to coronavirus. After reimbursing healthcare related expenses attributable to coronavirus that were unreimbursed by other sources, providers may use remaining PRF funds to cover any lost revenue, measured as a negative change in year-over-year actual revenue from patient care related sources.
For a complete post-payment notice of reporting requirements, please go to: https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-october-2020.pdf
CY 2021 Final Rule is Here
On October 29, 2020, CMS issued a final rule [CMS-1730-F] that updates the Medicare Home Health Prospective Payment System (HH PPS) rates and wage index for a calendar year (CY) 2021. The final rule adds an estimated $390 million home health payment boost for agencies in 2021 or an aggregate increase of 1.9%. In addition, this rule also finalizes regulatory changes related to telecommunications technologies in providing care under the Medicare home health benefit beyond the COVID-19 PHE, addresses home health certification by non-physician practitioners, and finalizes the adoption of a 5 percent cap on wage index decreases in CY 2021 only. Finally, this rule updates the
CY 21 penalty for delayed Request for Anticipated Payment (RAP) submission and describes requirements for home infusion therapy services.
For a complete CY2021 Final Rule, please see attached document.
In the subsequent weeks we will be individually discussing each of the areas addressed in the Final Rule. For today’s discussion, let’s review penalty for delayed Request for Anticipated Payment (RAP) submission going into effect on January 1, 2021.
Penalty for Delayed Request for Anticipated Payment (RAP) Submission
In the CY 2020 CMS finalized that HHAs that were certified for participation in Medicare with effective dates prior to January 1, 2019 (existing HHAs), would continue to receive split-percentage payments upon implementation of PDGM, but the up-front payment would be decreased from 60/40 percent to 20/80 percent.
Starting in CY 2021, the split-percentage payment would be lowered to 0 percent for all HHAs (newly enrolled and existing). However, all HHAs would still be required to submit a RAP at the beginning of each 30-day period of care (“no-pay” RAP). Since no payment will be associated with the submission of the RAP in CY 2021, HHAs are to submit the RAP when:
- The appropriate physician’s written or verbal order that sets out the services required for the initial visit has been received and documented as required; and
- The initial visit within the 60-day certification period has been made and the individual is admitted to HH care.
Note: In instances where the plan of care dictates multiple 30-day periods of care will be required to effectively treat the beneficiary, HHAs will be allowed to submit RAPs for both the first and second 30-day periods of care (for a 60-day certification) at the same time to reduce provider administrative burden.
In addition, for CY 2021, there will be a non-timely submission payment reduction when the HHA does not submit the RAP within 5 calendar days from the start of care date (“admission date” and “from date” on the claim will match the start of care date) for the first 30-day period of care in a 60-day certification period and within 5 calendar days of the “from date” for the second 30-day period of care in the 60-day certification period.
For example, if the start of care for the first 30-day period is January 1, 2021, the “no-pay” RAP would be considered timely-filed if it is submitted on or before January 6, 2021.
1/1/2021 = Day 0 (start of the first 30-day period of care)
1/6/2021 = Day 5 (A “no-pay” RAP submitted on or before this date would be considered “timely-filed”.)
1/7/2021 and after = Day 6 and beyond (A “no-pay” RAP submitted on and after this date will trigger the penalty.)
The penalty will be equal to a 1/30th reduction to the wage and case-mix adjusted 30-day period payment amount for each day from the HH start of care date/admission date, or “from date” for subsequent 30-day periods, until the date the HHA submits the RAP. The 1/30th reduction would be to the 30-day period payment amount, including any outlier payment, that the HHA otherwise would have received absent any reduction.
For example, if an HHA submits their “no-pay” RAP one day late (with a submission 6 days after the start of care), the result would be a 20 percent reduction to the 30-day payment amount.
Please note that in addition to the penalty, for LUPA 30-day periods of care in which an HHA fails to submit a timely RAP, no LUPA per-visit payments would be made for visits that occurred on days that fall within the period of care prior to the submission of the RAP.
The payment reduction cannot exceed the total payment of the claim.
The payment reduction for the late submission of a RAP can be waived for exceptional circumstances as noted below:
- Fires, floods, earthquakes, or other unusual events that inflict extensive damage to the HHA’s ability to operate
- An event that produces a data filing problem due to a CMS or MAC systems issue that is beyond the control of the HHA
- A newly Medicare-certified HHA that is notified of that certification after the Medicare certification date, or which is awaiting its user ID from its MAC
- Other circumstances determined by the MAC or CMS to be beyond the control of the HHA.
The HHA will need to provide sufficient information in the Remarks section of its claim to allow the MAC to research the exception request.
Don not miss an opportunity to attend the next Home Health, Hospice & DME Open Door Forum scheduled for Wednesday, November 4, 2020 PM at 1:00-2:00 PM Eastern Time (ET).
At this time, the Agenda for the Open Dorr Forum is as follows:
- Opening Remarks
- Chair – Brian Slater, Center for Medicare
- Moderator – Jill Darling (OC)
- Announcements & Updates
- CY 2021 Home Health Prospective Payment System Final Rule
- Correction to Change Request 11855, Penalty for Delayed Request for Anticipated Payment (RAP) Submission
- Home Health Quality Reporting Program
- Resource Materials
- Introduction to the Home Health Quality Reporting Program
- Updated version of the Guide to Home Health Help Desks
- HHQRP Non-Compliance Notifications
- Public reporting
- Launch of Care Compare and Provider Data Catalogue in early September (replacing Home Health Compare)
- October Refresh of Compare
- January 2021 Update of Care Compare
- iQIES Reports
- Public Reporting Decisions due to COVID-19 data exemptions
- Resource Materials
- Home Health CAHPS update
- Hospice CAHPS update
- HQRP updates
This call will be Conference Call Only.
To participate by phone, dial: 1-888-455-1397 & Reference Conference Passcode: 9375124
Please do not hesitate to reach out for any assistance or questions via email, phone, or website at https://amityhealthcaregroup.com/resources/
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Irina Gorovaya, RN BSN, MBA
Amity Healthcare Group, LLC
Home Health Consulting, Education and Outsourcing Services
720-353-7249 (cell) 303-690-2749 (office) 720-398-6200 (fax)