The National Association for Home Care & Hospice has been working closely with Palmetto GBA, the J11 Medicare Administrative Contractor (MAC), on relief for home health agencies impacted by the Requests for Anticipated Payment (RAP) Payment Suppression project that went into effect this past week.
Yesterday, a Palmetto spokesperson informed NAHC that PGBA began reinstating RAPs for certain home health agencies subject to the RAP suppression. These HHAs will receive immediate relief based on reinstatement criteria instituted by PGBA and CMS. The criteria include submission of an acceptable rebuttal letter and corrective action plan and:
- A percentage of RAPS to final claims that demonstrates that RAPS submitted during the last quarter of 2012 and during the period of January 2013 through April 2013 had final claims submitted, and
- The agency is otherwise in good standing.
PGBA is also working on refinements to the RAP suppression standards that will be applied prospectively in evaluating the status of HHAs with auto-cancelled RAPs. NAHC has recommended that the standards and process be revised to better target providers that present program integrity risks to Medicare. PGBA has already included one such refinement in its standards by considering the percentage of RAPs to final claims in evaluating rebuttals submitted by HHAs.
Palmetto indicated that it has received approximately 50 rebuttal letters and corrective action plans as of yesterday. With 298 HHAs subject to the suppression, the remaining HHAs are advised to submit rebuttal letters and corrective action plans quickly if they wish to be considered for immediate reinstatement. Palmetto further indicates that it plans to release RAP payments to a significant number of the HHAs that have already submitted letters. Once agencies that are approved for removal of RAP payment suppression they will receive payment for all RAPS submitted from that point forward.
The rebuttal letters should provide an explanation as to the reasons for the provider experiencing a volume of auto-cancelled RAPs. These reasons can include, but are not limited to, changes in billing systems, unusual difficulties in securing physician certifications and documentation, and unexpected interruptions in the billing staff resources. A corrective action plan should address the remedies the HHA will employ to reduce or eliminate the risk of auto-cancelled RAPs in the future. PGBA expects to evaluate the incidence of auto-cancelled RAPs on a monthly basis.