NOA replacing RAP

Medicare manual updated in preparation for switch from RAPs to NOA on Jan. 1 2022

Medicare will do away with no-pay RAPs at the first of next year, but the change won’t provide relief from a five-day submission timeframe with hefty penalties for home health agencies failing to submit on time.

The RAP, or Request for Anticipated Payment, will be replaced by a Notice of Admission (NOA) which must be submitted to an agency’s Medicare administrative contractor within five calendar days from the start of care date.

“As with this year’s no-pay RAPs, there will be a reduction in payment tied to any late NOA submissions,” said J’non Griffin, President of Home Health Solutions, A Simone Coding Company.

The NOA will be a one-time submission that covers contiguous 30-day periods of care until the patient is discharged from home health services. A new NOA will be required to submit any additional claims once a discharge has been reported to Medicare. Some requirements currently in place for submitting the RAP will remain the same under the NOA. A verbal or written order from the physician will be required, and it must specify home health services required for the initial visit. Agencies must have conducted the initial, billable visit at the start of care. Full details are provided in a new version of Chapter 10 of the Medicare Claims Processing Manual, which has just been updated per CR 12256 to include instructions for submitting NOAs instead of RAPs effective Jan. 1, 2022. The Centers for Medicare and Medicaid Services (CMS) made available the revised version of Chapter 10 this week, and is asking agencies to begin educating their billers now about the new process.

“We’ve known this was coming, as CMS has been phasing out the RAP and stopped providing any upfront payment associated with the RAP this year,” Griffin said. “But CMS is letting agencies know that it’s time now to start preparing billers for these new changes coming in January 2022. "Agencies will want to make certain their billers review Change Request 12256, where the relevant manual sections have been provided so that billers may familiarize themselves now with the revised billing instructions and submission requirements," Griffin said. Click here to read the Change Request with the manual revisions.

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