RCD news from Palmetto

Workshops in Florida offered Review Choice tips, strategies and advice to home care providers


There's no official date yet for Florida, Texas and North Carolina to join Illinois and Ohio for the Review Choice demonstration, but Medicare administrative contractor Palmetto GBA offered some advice to home care providers in a series of workshops held in cities across Florida last week:

Don't wait to get ready.

The key to success under the demonstration is staging processes and paperwork for maximum efficiency, according to Palmetto representatives who answered questions and provided tips to attendees at five workshops sponsored by the Home Care Association of Florida.

The next state, as yet unannounced, could join the demonstration as soon as 60-90 days after it rolls out in Ohio, where home care providers are making their selections now for whether they will undergo pre-claim or post-payment review beginning Sept. 30 -- or opt out of the demonstration altogether and take a 25 percent reduction in reimbursement.

Palmetto representatives cautioned workshop attendees that the third option, to forego the demonstration and take a 25 percent cut in pay, could open the door to more scrutiny by reviewers than providers realize, as claims will not be insulated from ongoing efforts to detect fraud through ZPIC, RAC, UPIC and similar review processes.

Troublesome timing The 60-90 day timeframe means some agencies could find themselves joining the Review Choice demonstration at the same time the Centers for Medicare and Medicaid Services (CMS) implements its new payment model, the Patient-Driven Groupings Model known as PDGM, at the first of 2020.

"This is why home health agencies really can't waste any time in getting ready for these major changes," said J'non Griffin, owner and president of Home Health Solutions. "If you are in Florida, Texas or North Carolina, you need to be looking at your processes now to determine where you need to make changes to get faster and more efficient, and what you can do to make sure you have the necessary documentation." Palmetto reps cautioned that although CMS has identified Florida, Texas and North Carolina as the next states to join the demonstration, any state in the Palmetto jurisdiction could be placed under Review Choice after those states.

How to prepare

Palmetto reps offered these tips for home health agencies looking to shore up their processes in preparation for the demonstration: 1. Start using eServices now.

Any home health agencies not currently using the eServices Portal should make the switch prior to their implementation date and get used to it in advance, Palmetto advises.

2. Choose administrators carefully.

Multiple administrators will be required at each agency for overseeing the demonstration. Agencies attempting to rely on one administrator could be locked out of the electronic portal if the person designated as the administrator leaves the agency or becomes unavailable for any reason, so multiple administrators are advised. Choose carefully, considering that administrators will have full access to all information.

3. Evaluate the impact on cash flow. When determining whether to select pre-claim or post-payment reviews, agencies will need to consider the potential impact on cash flow. Under the pre-claim review option, an agency will be allowed to resubmit a pre-claim for affirmation multiple times, potentially stretching out the reimbursement process. Under the post-payment process, claims determined to have been


4. Decide how to handle calls. Agencies opting for pre-claim reviews will receive telephone calls from nurse reviewers who need to discuss the submissions. Agencies need to decide in advance how those incoming calls will be handled, as there will be no process in place for returning the call to the nurse reviewer. Nurse reviewers will not be allowed to leave voice messages. This means agencies will need to have in place a process in place for forwarding the incoming call to a person who has been designated to take it, or to set up a specific time for the nurse reviewer to call again. Specific training in how to handle these important calls will be needed for most agency receptionists, and a plan will need to be in place for how to get the call to the right person.


5. Get faster. Getting together the necessary documentation and getting it in a timely manner to the biller or to the person who has been designated to oversee Review Choice submissions at an agency is crucial to success, Palmetto reps said.

6. Document accurately.

Making certain all pieces of the paperwork are in place, and that documentation meets the demonstration requirements, is also important. Although the demonstration will not require any additional documentation for agencies, all required documentation will need to be adequately presented for review in an easy-to-read format. Agencies need to make certain staff members are clear now on what will be considered adequate documentation for the face-to-face encounter, how to quickly review all documentation and spot missing elements, and how to effectively document important aspects of eligibility such as homebound status and need for skilled services. We can help! Home Health Solutions offers products specifically designed to help agencies shore up their documentation. Our "Dirty Dozen" guide, available for just $24.99 in our online store, details the 12 common mistakes made by home care providers in their face-to-face documentation. It's a great tool to have on-hand as your agency heads into Review Choice.


Our "Review Choice 101" guide, sold for $99, provides 101 tips for creating documentation designed to pass reviewer scrutiny. With chapters targeting medical necessity and the F2F, it zeroes in on areas in which agencies are most vulnerable as they head into Review Choice. Plus, the entire guide is provided in quick-to-read checklist form for busy professionals! Plus, our brand new "RCD Staff Training Guide" -- a resource designed specifically for making certain your agency staff understands the RCD requirements -- will be added to our online store in the next few days! Check out all our helpful compliance products here!

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