The largest home health and hospice Medicare Administrative Contractor (MAC), Palmetto GBA, has taken steps to suppress payments to home health agencies described as having a “high number” of auto-cancelled Requests for Anticipated Payment (RAP). The National Association for Home Care and Hospice (NAHC) identified 298 home health agencies whose RAP payments have been suppressed due to the failure to submit timely final claims as required, which led to RAPS being auto-cancelled. In the targeted agencies, 100 or more RAPS have been auto-cancelled and several agencies had more than 1,000 RAP cancellations. At least one agency had over 4,000 RAP cancellations.
For these 298 home health agencies, Palmetto has stated “RAPs will be set to pay at zero percent. The payment suppression will continue until a Corrective Action Plan is submitted and the provider can demonstrate improvement in timely billing of final claims.”
The Palmetto GBA bulletin informing home health agencies of RAP payment suppression states:
“Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim. If the final claim is not submitted within the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim. RAPs auto-cancelled for no submission of a final claim should be minimal.”
In addition to agencies being notified of immediate RAP payment suppression, warning letters are being sent to agencies that had between 50-100 auto-cancelled RAPs during the same time period, notifying them that their current billing practices are unacceptable, and that their RAPs are being monitored. If improvement is not noted, their future RAPs may also be set to pay at zero percent.
HMS would like to advise home health agencies to monitor their RAPs without finals and analyze the revenue cycle from intake to final claims to correct the issues holding the final claims. RAP suppression cripples an agency’s cash flow, so whether it’s Face to Face or physician orders, address the issue and then stay on it until your percentage of canceled RAPs is much less than the 50 threshold.
If you would like an assessment of your risk for RAP suppression, please contact Cheryl Leslie, Director of Home Care and Hospice Services at email@example.com.