The 5-day RAP in 2021


There's no upfront payment for home health agencies in 2021 -- but a late RAP will incur a hefty penalty

Although there will no longer be any upfront payment for Medicare episodes of home health in 2021, it's more important than ever for home health agencies to submit the Request for Anticipated Payment (RAP). Failing to submit the RAP within the first five days of the beginning of each 30-day billing period will cost agencies stiff penalties for each day the RAP is late. "This has many agencies really worried about how this is going to work," said J'non Griffin, President of Home Health Solutions, a Simione Coding Company. "But there's a great deal of misunderstanding and misinformation out there, and fortunately it may not be as difficult as some agencies are worried about." The criteria used for RAP submission is changing, too, which will simplify the process, according to Griffin. Although the first billable visit must be completed and the agency must have written or verbal physician's orders prior to submitting the RAP, the Centers for Medicare and Medicaid Services (CMS) has done away with some other submission requirements and made a few previous requirements optional. These changes should make a timely submission process possible for agencies which have in place effective processes to monitor RAPs and make certain penalties are not incurred, Griffin said. "The penalties will be important to avoid, as they are significant," she said. Ahead for 2022 Although agencies will receive no advance payment in 2021 in return for submitting RAPs, the process is expected to prepare them for a major change the following year, when CMS will do away with RAPs altogether, and require agencies to file a Notice of Admission (NOA) instead.

Beginning on Jan. 1, 2022, the NOA will work much the same as the 2021 RAP process. Agencies will be required to file within 5 days of the beginning of the patient's home health episode or be penalized for each late day. Join us for a Nov. 11 webinar

Griffin will join a panel of Simione Healthcare Consultants for a complimentary webinar Wednesday, Nov. 11, from 2-3 p.m. Eastern time to review the new RAPs requirements and provide best-practice approaches to avoid penalties and achieve quality outcomes in tandem with timely, accurate billing and coding for stronger financial results. The 60-minute webinar will provide a brief overview of the Final Rule for 2021 approved by CMS last week, summarize RAPs changes and review concerns about handling coding and OASIS, billing and selection of HIPPS codes as related to RAPs changes. Griffin will be joined by Rob Simione, Director of Financial Consulting for Simione, Kimberly Chapman, Senior Manager of Financial Consulting for Simione, and Michael Simione, Manager of Finance and Data Analytics for Simione.  Click here to register now for the Nov. 11 webinar.

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