UPDATE: Palmetto GBA RAP Suppression

Palmetto GBA announced that it is in process of restoring RAP payments to agencies which have submitted Corrective Action Plans or Rebuttals that meet their requirements. If the provider is making strides in reducing the number of auto-cancels, is filing a majority of their finals timely when compared with auto-cancels, and are in good standing, Palmetto is restoring their RAP payments at 60% as new RAPs are received.

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. The home care industry 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.

If your agency is one of the 298 across Palmetto’s 16-state jurisdiction, please submit a Corrective Action Plan (click here to download a template) with a statement¬†asking to be removed and why you are making the request. Palmetto’s fax number is (803) 935-0140.


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