Dear Members, CMS has announced that the Review Choice Demonstration (RCD) for Home Health Services is pending Paperwork Reduction Act (PRA) approval for its initial implementation in the state of Illinois; this is a delay from the planned Illinois implementation scheduled for December 10, 2018.CMS will post an update on the program and instructions for choice selection once final approval is given. The RCD will be implemented in phases, beginning in Illinois, with Ohio, North Carolina, Florida and Texas to follow at a later date.Background on the Review Choice Demonstration from CMS
Following the postponement of the Pre-Claim Review Demonstration for Home Health Services on April 1, 2017, CMS worked to revise the Demonstration to offer more flexibility and choice for providers, as well as risk-based changes to reward providers who show compliance with Medicare home health policies. The proposed Review Choice Demonstration for Home Health Services will give providers in the demonstration states an initial choice of three options – pre-claim review, postpayment review, or minimal postpayment review with a 25% payment reduction for all home health services. A provider’s compliance with Medicare billing, coding, and coverage requirements determines the provider’s next steps under the Demonstration. CMS will implement the Demonstration for the Home Health and Hospice Medicare Administrative Contractor Jurisdiction M (Palmetto) providers operating in Illinois, Ohio, North Carolina, Florida, and Texas for five years, with the option to expand to other states in the Palmetto/JM Jurisdiction.
The revised Demonstration will assist in developing improved methods to identify, investigate, and prosecute potential fraud in order to protect the Medicare Trust Funds, potentially reduce the rate of improper payments, and improve provider compliance with Medicare rules and requirements. Through either pre-claim or postpayment review, the Demonstration will help make sure that payments for home health services are appropriate.
The Review Choice Demonstration for Home Health Services should not delay care to Medicare beneficiaries and does not alter the Medicare home health benefit. The Demonstration will not create new clinical documentation requirements. Providers will submit the same information they are currently required to maintain for payment. Under the pre-claim review option, the pre-claim review request may be submitted at any time before the final claim is submitted and can occur after home health services have begun. Under the other review options, the provider will receive an Additional Documentation Request (ADR) and follow the normal processes for claims chosen for review.
Upcoming TAHC&H Session on Review Choice Demonstration
Despite the delay, providers should start preparations now rather than wait to implement the operational changes needed to be successful with RCD. In order to ensure you are prepared, TAHC&H will feature a session on the Review Choice Demonstration presented by Krisdee Foster from Palmetto GBA during our Winter Conference, to be held in Austin on February 13-14, 2019. Ms. Foster will provide an overview of the demonstration using all current CMS guidance. She will also answer questions and provide valuable insight into how providers should use the portal, and the process Palmetto GBA review staff will use to process each affirmation request. This will be a first look at the RCD program prior to its implementation.
Following Ms. Foster's presentation, attendees will also hear from Illinois provider Cheryl Adams, who achieved 100% affirmation in the first roll out of Pre- Claim Review, without having to add additional staff. Ms. Adams will provide operational tactics and advice to help agencies implement process changes at their own agencies to ensure a high affirmation rate.
As always, please submit any questions you have to TAHC&H; we're happy to help!
Thank you,
Heather