RCD in Florida, North Carolina

Florida and North Carolina providers are choosing Pre-Claim Review option

Despite coronavirus pandemic, home care providers making Review Choice selections for April 19 deadline

While home care providers across the nation scramble to shore up infection control measures during the coronavirus pandemic, making decisions about how best to protect their patients and staff, agencies in Florida and North Carolina are also deciding how they want their claims reviewed for errors.

Providers in those states must tell Medicare administrative contractor Palmetto GBA by April 19 whether they want reviewers to scrutinize their documentation for errors before or after claims are submitted for payment.

“The Review Choice Demonstration scheduled to roll out to Florida and Texas later this spring has not been postponed or delayed by the COVID-19 pandemic at this time,” said J’non Griffin, owner and president of Home Health Solutions, a nationwide consulting and outsourcing firm.

Under Medicare’s Review Choice Demonstration, agencies must choose whether they prefer to have reviewers scrutinize their documentation in a pre-payment or post-payment process. An additional option allows agencies to choose a substantial overall financial penalty instead – but agencies taking that option will still be subject to minimal fraud review.

Selection underway now

The selection process for Florida and North Carolina began Friday, despite growing concerns about the impact the COVID-19 pandemic is already having and is expected to continue to have this spring on home health.

So far, the Centers for Medicare and Medicare Services (CMS) has not postponed its planned May 4 rollout of the demonstration in Florida and North Carolina. They will become the last two of five states targeted for the demonstration, joining Illinois, Ohio and Texas. Texas providers just entered the demonstration March 2, and many are still struggling to understand the RCD process as they deal with Medicare's new payment model, the Patient-Driven Groupings Model (PDGM) implemented at the beginning of the year, and now the COVID-19 pandemic.

“Agencies everywhere have been working diligently to make sure they have emergency plans in place to maintain infection control procedures. They’re also having to figure out how to handle some very serious issues such as expected staffing shortages due to sickness and lack of child care – and what to do about shortages of personal protective equipment,” J’non said.

“In Florida and North Carolina, where providers are busy with these vitally important emergency measures, they will still need to visit the Palmetto portal and make a selection,” J’non said. “Unless CMS postpones the rollout in these two states, which has not been done at this point, agencies will need to make this important decision by April 19.”

Agencies which do not make a selection by the deadline will automatically be placed in the post-payment review process, with 100 percent of all claims reviewed after payment.

Statistics provided on the Palmetto web site indicate that less than a week into the process, providers in both Florida and North Carolina are selecting the pre-claim review option over other choices.