RAP Update for 2021
Though the RAP (request of anticipated payment) will be around in 2021, it will be in name only. There will be no payment tied to it, rather it will on be used operationally for the Medicare program to establish the beneficiary’s primary HHA in the common working file (CWF). This will allow claims processing system to reject claims from providers or suppliers for items and services subject to consolidated billing, other than those from the primary HHA. In 2022, the NOA (notice of Admission) will serve this purpose for CMS.
2020 marks the first year that HHA have been required to bill for the separate 30-day periods inside a 60-day care episode. Just as we start to get used to the 30-day RAP billing there will be some changes beginning in 2021.
Currently, for initial episodes/periods of care, the HHA reports on the 0023 revenue code line the date of the first covered visit provided during the episode/period. For subsequent episodes, the HHA reports on the 0023 revenue code the date of the first visit provided during the episode/period (known as the first billable visit), regardless of whether the visit was covered or non-covered.
The one exception is if there are no visits expected during a 30-day period of care. In this case, the agency should submit a RAP with the first day of the period of care as the service date on the 0023 line. This will keep the common working file up to date with the patient’s status as a home health patient. This RAP for a period with no visits, but continued home health admission status, will be autocancelled when the final claim is not received within 90 days of the start date of the RAP or 60 days from the RAP paid date, whichever is greater, and any payment recovered.
There has been concern verbalized by HHAs who are looking at the looming 5-day RAP penalty. Will they be penalized for patient's with long term low utilization such as those with catheter changes or port maintenance, who's first billing may not be in the first 5 days of any 30-day period?
CMS came out with new guidance last week regarding RAPs and first billables in 2021.
Read the MLN Matters 11855 here
Read the full length Pub 100-04 Medicare Claims Processing Change request 11855 here
Since there will be no payment on the RAP in 2021 there will no longer be any reason for the MACs to autocancel RAPs. CMS has also stated that HHAs may submit RAPs for both the first and second billing period inside an episode immediately after the start of the 60-day certification period. The service date for RAPs for all subsequent periods will be the first date of the prospective period--Not the first billable visit. In this way, agencies no longer need to be concerned about the 5-day RAP penalty being triggered by a low utilization patient frequency. In fact, CMS seems to be encouraging HHAs to bill both 30-day RAPs for a 60-day certification period upfront if there is sufficient evidence to expect the patient to require more than the initial period of 30-days of care.
For a quick reminder of the RAP requirements in 2021 click here
For a breakdown of how the 5-day RAP / NOA penalty works click here
