CMS phasing in RCD

Aug. 31 implementation in Florida and North Carolina will be a phased-in process

A phased-in approach will be used over a 60-day period to introduce home health agencies in Florida and North Carolina to the Medicare’s Review Choice Demonstration (RCD), according to an announcement today on the Centers for Medicare and Medicare Services (CMS) web site.

The reprieve followed intense lobbying efforts from Florida agencies, who sent more than 11,500 e-mails over the past few weeks to CMS and lawmakers, protesting plans by CMS to add Florida and North Carolina to the demonstration on Aug. 31.

“There’s a sense of relief among providers in these states, who were genuinely worried about the impact of RCD during the Covid-19 public health emergency,” said J’non Griffin, president of Home Health Solutions, a Simione Coding Company.

Griffin is interacting with many Florida agencies during this week’s virtual Home Care Association of Florida conference, and she said RCD has been a topic of major concern for most of them.

“The phased-in implementation of RCD for Florida and North Carolina means providers in those states may still go ahead and participate beginning Aug. 31 if they choose – but they will not be required to submit their documentation for a pre-claim review process, and they will not be penalized with a 25 percent reduction in payment if they choose not to participate,” Griffin said.

Agencies which do not participate may still be subject to post-payment review under the normal medical review process, Griffin noted. However, claims which go through the pre-claim review process with a valid Unique Tracking Number (UTN) will be excluded from further medical review.

CMS said it will reassess the phase-in implementation of RCD after 60 days to determine whether to extend the phased-in implementation.

Texas, Ohio and Illinois

Home health agencies in Ohio, Texas and Illinois are already undergoing the demonstration, and the decision to phase in implementation in Florida and North Carolina will not impact previously established timelines for beginning additional cycles of the demonstration in those states, Griffin said.

CMS has said Cycle 2 will still begin for Ohio agencies on Aug. 31 as planned. In Illinois, Cycle 2 will end on Sept. 30 and in Texas, Cycle 1 will end on Sept. 30.

To calculate affirmation and approval rates in those states, CMS will use review decisions made between Feb. 1 and Sept. 30 for Illinois providers and between March 2 and Sept. 30 for Texas providers.

CMS said providers in those states who selected Choice 1 will still be subject to prepayment review, but until further notice, they will not be subject to a 25 percent reduction if they choose not to go through the pre-claim review process.

What should your agency do?

Agencies that have already made their selection for a review option will not need to take any further action, even if they choose not to participate in the pre-claim review process at this time, Griffin said.

However, Griffin said it is important for agencies to begin making at least some pre-claim submissions as quickly as possible to become familiar with the process and identify any areas for correction. Although CMS is offering leniency, it will expect at least some participation, she said. Griffin also strongly encourages home health providers in Florida and North Carolina to continue making preparations to join RCD by reviewing agency processes, training staff or seeking outside help to organize documents and make submissions. In the meantime, providers in Texas, Ohio and Illinois should focus on identifying their vulnerabilities and try to shore up agency processes to meet RCD demands, she said.

“This is a reprieve, but it doesn’t mean RCD has gone away,” Griffin said.

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