New regulations regarding payment programs have been designed to ease regulations on home health agencies (HHAs). They were enacted by the Center for Medicare & Medicaid Services (CMS) as part of their reform of the Home Health Prospective Payment System (HHPPS). Though in the long run these changes are expected to ease the business of running an HHA, in the short run, adjusting to these changes may be problematic. As with all change, there are new things to get used to and adjustments that stakeholders must make. In this article, we will look at the effect of these changes and the software options for revenue cycle management in home care.
Changes to Request for Anticipated Payment Claims
According to the changes to the HHPPS, in 2020, HHAs got 20% of their payment upfront whenever they filed requests for anticipated payment claims (RAPs). This was a reduction from the 50-60% of upfront payment that HHAs used to get. Added to this, HHAs had to file RAPs every 30 days. This was due to changes to billing within the Patient Driven Groupings Model (PDGM). Billing cycles shrunk from 60-day cycles to 30-day cycles within each 60-day period of care.
Since January 2021, the upfront payments are no longer paid. Not only that, HHAs had to submit no-day RAPs within five days of every 30-day cycle, or face penalties. This means that HHAs have to file more paperwork to remain compliant. No-day RAPs exist because it is felt that it’s important to communicate upstream to the payment system that there is a Medicare beneficiary currently undergoing treatment at home.
Changes are still underway. In 2020, there will no longer be any RAPs. What will happen is that HHAs will have to fill out a notice of admission (NOA) for each Medicare beneficiary, within five days of that beneficiary receiving home health care. This will be a one-time process.
This is a lot of reform for any HHA to take, even, as it seems, the changes are being made to poush the system to a point at which HHAs have as light a regulatory burden as is possible.
Navigating these changes, as an HHA or provider of senior day care center, requires a few adjustments.
Improve Data Capture in the Intake Period
WHat you want to do at a time of heightened paperwork, is to dramatically scale up your capacity to capture patient and client data in the intake period. Missing or incomplete information can have awful consequences for you on a compliance level. Before making any filings, ensure that you have all necessary and sufficient data. To achieve this, you should invest in electronic health record (EHR) software. This will improve your ability to capture data by prompting the person filling out the client information forms, to submit what information is needed. EHR software can also be used to check if new referrals should have overlapping home health episodes and it can then notify billing. This has the effect of reducing the number of claims that you need to submit in the event that a Condition Code 47 is needed.
EHS software can also be used as backup in the event that you need to verify insurance.
Schedule Filing of Claims
EHS software can also be used to schedule filing of claims. Given the increase in filing requirements, this is a huge plus and a help for HHAs. You can use a weekly collections plan in which you rank claims according to filing days and their accounts receivable balance. You can also identify trends in the data that can help you understand the payer better. The best EHRs will enable you to automatically release RAPs as soon as some threshold is reached.