CMS to resume Review Choice

Coronavirus numbers are climbing. Florida and Texas could be the nation’s new hot spots – but CMS says RCD will resume in August

The number of newly diagnosed COVID-19 cases in Florida surged toward the 10,000 mark between Tuesday and Wednesday, and 41 hospitals across the state reported no available hospital beds. Meanwhile, Texas saw its own coronavirus numbers top 9,900 on Wednesday, narrowly missing its record-setting 10,000 new cases reported the day before. But as Florida and Texas grapple with the potential to become the nation’s new coronavirus hotspots, and home health agencies brace for increasing numbers of patients, home care providers learned Wednesday that they are back in the crosshairs for Medicare’s burdensome Review Choice Demonstration, or RCD. The Centers for Medicare and Medicaid Services (CMS) announced Wednesday that it plans to resume RCD on Aug. 31, impacting agencies in Florida, Texas, North Carolina, Ohio, and Illinois. “There’s a great deal of concern among all home health agencies over the timing in trying to resume RCD at such an uncertain time, during the ongoing public health emergency,” said J’non Griffin, Owner and President of Home Health Solutions, a nationwide consulting and outsourcing firm for home health, hospice and long-term care. “And that is especially true in Texas and in Florida, given the rising numbers of COVID-19 diagnoses in those states. Most home health agencies are alarmed by the prospect of resuming RCD under these circumstances -- or, in the case of Florida and North Carolina, implementing it for the first time,” J’non said. New for Florida and North Carolina Home health agencies in Illinois have been dealing with RCD under a different name and slightly different rules since 2016, when it was known as the Pre-Claim Review Demonstration. Ohio joined the revamped demonstration in 2019, after it became RCD. Texas was the newcomer this year, the beneficiary of a slight delay in implementation which was supposed to give Texas agencies time to adjust to Medicare’s new Patient-Driven Groupings Model (PDGM) before tackling RCD. But Texas agencies had barely had time to adjust to either PDGM or RCD when the coronavirus led CMS to put things on hold this spring, scrapping immediate plans to expand RCD to other states. CMS also announcing that it would not enforce RCD requirements in states already participating in the demonstration. Both Florida and North Carolina were scheduled to join the demonstration on May 4. On March 20, they began making their choices for when they wanted their claims reviewed – either before submission for payment or post-payment. They had a third option as well, one widely considered unpalatable. That option allows agencies to bow out of RCD – but it slices 25 percent from Medicare reimbursement, and does not preclude regular audits for fraud. On March 30, CMS paused the selection process before it could be completed in Florida and North Carolina, and stopped enforcement of RCD in Texas, Ohio and Illinois. There was some expectation that the suspension of enforcement would last for the duration of the public health emergency, but on Wednesday, an announcement on the CMS web site stated that RCD will resume “regardless of the status of the public health emergency.” The new timeframe According to the new CMS timeframe, agencies in Florida and North Carolina will begin making their initial RCD selections on Aug. 3 and will have until Aug. 17 to complete the selection process. Agencies in Ohio will participate in the second phase of their selection cycle during that same time frame. Aug. 31 is the new D-Day, as in Demonstration Day. All billing periods that begin on or after that date in Florida, North Carolina, Texas, Ohio and Illinois will now be subject to RCD requirements. In addition, Medicare administrative contractor Palmetto GBA will take a look at claims which were submitted and paid during the pause, conducting post-payment reviews for all which are subject to the demonstration. “CMS said it will post more information on the post-payment review process in the near future,” J’non said. Swift outcry from agencies Reaction from agencies in Florida and Texas was swift and negative, with many agencies speaking out on industry Facebook groups and in email threads to share their concerns. Many agencies reported that it has been more challenging than ever before to acquire necessary physician signatures during the coronavirus, when many physicians are much less accessible. They expressed concern about being able to meet more stringent documentation demands and timeframes under RCD when the coronavirus continues to impact physician offices. Some agencies also said they are already struggling financially, and are worried that having to pay additional administrative costs to handle RCD processes could be a tipping point. Coronavirus figures in RCD states In Florida, the state's Agency for Healthcare Administration reported an increase of 9,989 new cases between Tuesday and Wednesday, bringing the state to a total of 223,793 diagnosed cases of the coronavirus. Only 15.36% of the state’s adult ICU beds remained available as hospitals across the state reported operating at capacity. In Texas, the numbers were equally alarming. On Wednesday, 9,979 new coronavirus cases were reported on Wednesday after hitting a record-high 10,028 cases the day before. Another grim record was set Wednesday with the highest number of deaths reported in the state so far. The coronavirus impact looks slightly less fearsome in North Carolina, where the North Carolina Department of Health and Human Services reported a slight decline in COVID-19 cases between Monday and Wednesday. However, at least 75,875 people in North Carolina have tested positive for the coronavirus, and health officials there reported 1,420 deaths. In Ohio and Illinois, the numbers of new cases are also rising. Ohio relied on its new color-coded system this week to order seven counties to require masks as the number of new cases escalated on Wednesday, exceeding the state’s 21-day average. Illinois also saw an uptick in new cases on Wednesday and a higher number of deaths, following a relatively flat curve since the end of June. “These latest figures indicate that the coronavirus remains a very serious issue in these five RCD states, ” J’non said. HHS can help If your agency is worried about meeting RCD demands under such challenging circumstances, Home Health Solutions has the help you need. We can assist you in setting up new RCD processes and workflow designed to help meet new requirements – and we can assist you in your pre-claim submissions. Reach out to us here to ask for help.

Be sure to browse the Home Health Solutions online store for products specifically designed to help agencies, such as our brochure template designed to put all the necessary information about RCD requirements and deadlines into the physician’s hands in a quick-read format. The template is provided in WORD format so that your agency can easily add your logo or tweak any wording. Just print it, fold it, and take it to the physician who needs more information. During our Summertime Savings event, the brochure template is on sale right now for just $17.99. Click here to take a look now! Read the CMS announcement about RCD here.

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