Review RAP Submission/Cancellation Trends Within Your Agency.
Palmetto GBA recently started monitoring the number of RAPs that are auto-canceled due to providers not filing a final EOE claim. In doing so, they have begun suppressing payments to home health agencies identified as having a “high number” of auto-canceled Requests for Anticipated Payment (RAP). The high number is currently set to 100 or more RAPs auto-canceled between January 1 and April 15, 2013. Providers who meet this criteria will receive a letter from Palmetto GBA informing them that their RAPs will be suppressed.
Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim. If the final claim is not submitted within the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim. Auto RAP cancellations are expected to be minimal.
Palmetto GBA website provides steps that home health agencies should take to have their RAP payment suppression lifted, including submission of a Corrective Action Plan.
The National Association of Home Care and Hospice (NAHC) recently reached out to Palmetto GBA to get clarification on the payment suppression to try and establish a reasonable implementation process to prevent agencies from being unfairly targeted. Even providers who are not currently impacted by the RAP payment suppression may want to review RAP submission/cancellation trends within their agencies to identify what factors currently cause EOEs to not be submitted in a timely manner. NAHC is recommending that home health agencies cancel RAPs before they are auto-canceled, if they believe they will be unable to submit the final claim before the 120 days.
HEALTHCAREfirst agencies who use the Revenue Intelligence module of Business Intelligence can track auto-cancellations on the “RAP Submissions by Week” Dashboard.
As additional information is published regarding RAP monitoring HEALTHCAREfirst will post updates to the blog.