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“Troublesome Transition Year”: Why 2021 Looks Different in Home Care with New RAP Adjustments

The Medicare & Medicaid Service Center (CMS) in the United States issued the final 2021 home health care payment rules in late October. Some providers weren’t happy when it came out.

On the one hand, the patient-led grouping model (PDGM) has not been substantially modified to balance the assumptions of defective behavior. The other is that there are some “quirks” in the rules that make 2021 a unique and potentially complex year.

Overall, the final rule will add an estimated $ 390 to home care facilities next year. This is roughly equivalent to a 1.9% increase in payments. These numbers are less than a $ 540 million boost, an increase of 2.6% that first appeared in the CMS’s proposed rules.

Since the final rule was announced, providers have learned more about the fines associated with Delayed Expected Payment Requests (RAPs). RAP will be phased out next year, but providers will need to submit a “free RAP” within 5 calendar days of the start of care.

Under the Future Payment System (PPS), agencies can receive 50% to 60% of payments in advance. This year, existing agencies have been reduced to 20% and new agencies have been locked out of RAP.

In 2021, there will be no payments associated with RAP to anyone. When RAP is completely phased out in 2022, Admission Notice (NOA) will be used instead.

“Therefore, this was a fairly standard annual update from Medicare, especially given what we experienced in the transition to PDGM last year,” McBee Associates consulting manager Matt McGowan said in a recent webinar. I am. “But with the 2021 RAP, we have to go through such a nasty transition year. It’s a blend of the familiar RAP and the process under the 2022 NOA.”

Based in Wayne, Pennsylvania, McBee Associates is a healthcare services and consulting firm that provides financial, operational, and clinical support to healthcare providers throughout the continuum.

Although RAP is being phased out, submitting a RAP is a way for a CMS to track home care patients and whether they can only raise money through Medicare’s home care benefits. The agency encourages providers to continue to submit these RAPs by taking fines that count all days after the first day as fines if the provider misses the five-day period.

This means that RAP fines will only occur after the 5th day, but if the provider submits them on the 6th day, one-thirtieth of those five-day payments will also be docked and a 20% fine will be imposed. .. ..

It (and another habit of the final rule) will put some mines on the path of home health care providers in 2021.

For example, the RAP no longer offers payment, but the RAP still needs to be sent, which changes the entire provider’s coding process.

“Currently, we don’t have the funds associated with RAP, so Medicare says we don’t have to wait for OASIS and coding to complete to submit the RAP,” McGowan said. “Once you have accepted your order and completed your first visit, please proceed and submit your RAP.”

This will bring about major changes in the agency’s operational processes and workflows. However, there are still specific coding requirements related to the 2021 RAP.

“Here we face this annoying migration problem, because RAP still needs the primary diagnostic code and the HIPPS code,” McGowan said. “Medicare does not use RAP’s primary diagnostic code or HIPPS code for anything, so all RAPs can submit a common primary diagnostic code, such as hypertension.”

Therefore, the code is less important in advance, and government agencies can send common HIPPS codes such as 1AA11 on all RAPs.

But that’s not the end of the strangeness in the 2021 submission process. After the initial visit, RAP submission, ICD-10 coding, OASIS QA, and documentation are all complete, there is one more factor to note.

“When you submit that final claim, you need the same HIPPS code that was used in the RAP. The HIPP code in the RAP and the final claim must match,” McGowan said.

The CMS doesn’t use that HIPP code for anything, but it’s a rule that applies in 2021, so it’s imperative that the provider keep these codes in place.

“Troublesome Transition Year”: Why 2021 Looks Different in Home Care with New RAP Adjustments

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