RCD Delayed for Some, Not for Others
If you saw that CMS has delayed the review choice demonstration (RCD) -- that's partially true. When the public health emergency (PHE) started and CMS paused RCD it was a relief to some. However, the pause definitely came with strings attached...strings in the form of postpayment audits. Agencies who were paying attention to the pause in pre-claim review (PCR), noticed CMS intended to double back on claims submitted without a unique tracking number (UTN) explained in the Q&A exert below.
"Following the resumption of the demonstration, the MAC will conduct postpayment review on
claims subject to the demonstration that were submitted and paid during the pause. CMS will
work with affected providers to develop a schedule for postpayment reviews that not does
significantly increase provider burden. Claims that received a provisional affirmative pre-claim
review decision and were submitted with an affirmed Unique Tracking Number (UTN) will
continue to be excluded from most future medical review."
--https://www.cms.gov/files/document/provider-burden-relief-faqs.pdf
If you are in one of the demonstration states, I am hoping you didn't take CMS up of their offer to pause the demonstration but continued to submit your PCR as before. Those that chose to pause may find themselves submitting current claims for PCR while also under postpayment review for those claims excluded during the PHE.
CMS is now offering a delay... for agencies in North Carolina or Florida only. The kicker? Just as before agencies who choose not to submit claims for PCR may be subject to postpayment reviews in the future
"Claims may be subject to postpayment review in the future through the normal medical review process".....
If your agency has already been gearing up for PCR and has the ability to begin as originally scheduled on 8/31/20 it may be to your advantage. If your agency is struggling due to COVID-19 or just needs a little extra time, begin as soon as you can. Every claim that has a UTN will NOT be subject to further audit per CMS. Those agencies in North Carolina and Florida who join RCD / PCR as soon as they are able rather than waiting till CMS mandates their participation may benefit far more than agencies who don't.
Read the full CMS announcement here
