As the final phase of PDGM inches closer, home health agencies are preparing for RAPs to phase out and the Notice of Admission (NOA) to begin. This transition will be a welcome change, allowing agencies to revert to the one-claim-per-patient-per-month concept and to improve their RCM processes. Here are some actions to take now, before the final phase starts in January 2022.
1. Expect relief, but not complete relief.
While we’ve learned that the No-Pay RAP process has caused difficulties, the NOA implementation will come with its own set of compliance and regulation considerations. Home health agencies that fail to submit the NOA within five calendar days from the start of care date will see a payment reduction.
The good news is that only one NOA is required for any series of home health periods of care, beginning with admission and ending with discharge. If a patient is discharged and later readmitted, a new NOA is required.
2. Consider the transition guidance.
Included in the manual updates, the transition guidance states that for all patients receiving home health services in 2021, and whose services will continue in 2022, the home health agency (HHA) shall submit an NOA with a one-time, artificial admission date corresponding to the “from” date of the first period of continuing care in 2022.
For example, consider a period of care that begins in 2021, but ends on January 10, 2022. The HHA would then submit the NOA with an “admission date” of January 11, 2022, and submit a claim when the 30-day period of care is over.
3. Check eligibility continually.
It’s important to complete a head-to-toe assessment of your agency’s processes to ensure the success of NOA, starting with your intake process. If you are not yet checking eligibility, start doing so weekly or (at a minimum) monthly. Many software systems have this feature built in, making it easy to catch plan changes as early as possible to avoid an untimely NOA.
4. Start contacting your payors now.
Since billing and documentation requirements vary by MA plan, HHAs should reach out to their contracted MA plans to validate what their billing and documentation requirements will be in 2022. More questions to ask include:
- Will they require an NOA?
- Will there be a penalty for untimely NOAs?
- Will there be requirements on claims if the NOA is late?
- Will they be following the same exceptions?
- Will RAPs still be required?
- Will they require a final claim and no NOA or no RAP?
It’s important to have these conversations now, so you can be better prepared for what’s coming in 2022.
5. Discover your EHR.
Talk with your technology partner to discover how they’re preparing for NOA. Review NOA release notes, sign up for webinars, and be prepared to reconcile using an admissions report to ensure nothing is missed.
6. Be mindful of staffing in January.
Entering the NOA for each transition patient will put an administrative burden on your billing team this January. During this time, be mindful of how you staff your agency, so you’re prepared for the coming changes.
By taking these actions now, your agency can start improving revenue cycle management, well before the final phase of PDGM goes into effect.
To learn more about HEALTHCAREfirst’s full-service approach to RCM, CAHPS, and advanced analytics solutions for home health and hospice agencies nationwide, schedule a meeting with our experts.