Home Health Articles and Information

Quick guide to NOA 2022

The Notice of Admission (NOA) is coming January 1, 2022.

Here is a quick guide to help your agency have a smooth transition.

• The NOA should be sent on every home health patient with an admission date on or after 1/1/22.
  
  
• The NOA only needs to be submitted once at the beginning of an “admission period”. This is the start of care through the discharge of the patient.
  
  
• The NOA can be submitted through the EMR or entered into the DDE directly.
  
  
• If a patient is discharged from home health then readmitted a new NOA is required.
  
  
• The NOA must be SUBMITTED and ACCEPTED by the MAC within 5 calendar days after the admission date (from date).
  
  
• The requirements to submit the NOA are-

1. 1.  A verbal or written order for admission received by the agency
      
   2. The initial SOC visit has been completed

Since the home health industry is familiar with the No-pay RAP, this transition should not be a difficult one.  However, please make sure you keep the two potential issues below in mind as you transition your agency.

1. Transitioning episodes that start in 2021 but end in 2022

“…the HHA shall submit an NOA with a one-time, artificial 'admission' date corresponding to the "From" date of the first period in 2022.”

If your SOC was on 12/31/21 (or before) you would submit a RAP for the period starting on 12/31/21. Then you would submit your one-time NOA on the “artificial admission date” 1/30/22 which is the first day of the 2^nd period of the episode.

2. How the non-timely filing penalties accrue

“Medicare shall reduce the payment for a period of care, including outlier payment, by the number of days from the home health admission date to the date the NOA is submitted to, and accepted by, the A/B MAC (HHH), divided by 30.”

The penalty for late submission of NOA starts from the first day of the 60-day episode of care or five (5) days after the initial visit, NOT the first day after the agency missed the deadline.

A late NOA submission is penalized at 1/30th of the expected payment per day applied from the date of admission, which represents a potential loss of 20% or more. This will particularly affect you if non-billable visits reduce the full payment to a Low Utilization Payment Adjustment (LUPA).

The No-pay RAP value in 2021 only covers a single 30-day period, then another no-pay RAP would be required for the second period. The NOA penalties in 2022, are from the beginning of the episode of care to the time that the NOA is accepted or the episode ends... For instance, if the NOA is 45 days late next year, then the agency will be penalized for 45 days, not just 30.

There are a few exceptions in which there will be no penalty for a late submission, they are the same exceptions that covered the no-pay RAP in 2021

• 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 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; or

• Other circumstances determined by CMS to be beyond the control of the HHA.