CMS pauses Review Choice

RCD pause creates 'now or later' question about ADRs for home care providers

Medicare has paused its Review Choice Demonstration in Illinois, Ohio and Texas and will not roll it out as planned on May 4 in Florida and North Carolina.

The announcement came this week as the Centers for Medicare and Medicaid Services (CMS) handed down numerous regulatory waivers designed to ease the burden on health care providers during the public health emergency created by COVID-19.

However, there are questions about what the pause actually means for home health agencies, and whether it could create an additional workload of Additional Documentation Requests (ADRs) waiting for agencies once the public health emergency ends.

"We are still waiting on CMS to clarify some things for us," Home Health Solutions owner J'non Griffin said Wednesday. Selection process

In the meantime, J'non is recommending that agencies in Florida and North Carolina continue with the selection process they were undergoing prior to the anticipated launch in their states in May. That selection process began March 20, with agencies signing up via a secure portal on the Medicare administrative contractor Palmetto GBA site. No replacement date has been provided for the postponed May launch in Florida and North Carolina.

Option to continue Claims submitted on or after March 29 2020 in the three states where Review Choice was in progress will not be subject to review under RCD, although CMS has said agencies in those states do have the option of continuing with RCD processes if they choose.

If agencies which selected the pre-claim option choose to pause their RCD participation during the coronavirus crisis, it appears that all claims processed during the public health emergency could be subject to 100 percent post-payment review later.

In addition, agencies which selected the post-payment review and agencies operating under a "spot check" review system might be presented with Additional Documentation Requests (ADRs) at the end of the public health emergency for all claims during the crisis.

In either case, agencies could find themselves faced with a stockpile of ADRs on the other side of the public health emergency. The uncertainty of a "now or later" situation with ADRs has prompted many agencies to say they plan to continue with RCD review processes instead of taking advantage of the RCD pause.

Claims submitted prior to March 29 must still undergo the review process which the agency selected.