Updated on 03/29/2021

CMS continues RCD Phase-In for FL & NC

Author: Michael Tidd LVN, HCS-D, COS-C


Agencies located in Florida and North Carolina will continue to have the option to voluntarily participate in the Review Choice Demonstration or hold off on submissions for this program for an additional 90 days.  As you may know, these states ae among the five states (IL, OH, TX, FL, NC) required to participate in the Review Choice Demonstration.  This demonstration program was paused in March, due to the public health emergency that resulted from COVID-19,  resumed in late August.  Florida and North Carolina are the last two states to enter the demonstration and were scheduled to start mandatory submissions when the demonstration resumed.  NAHC was successful in lobbying CMS for authorization to postpone the resumption of RCD.  CMS was not willing to continue the pause and required IL, OH and TX to resume submissions, but did authorize FL and NC the choice to participate or hold off on submissions.


The benefit of choosing to hold off on participating in RCD revolve around easing staffing requirements, but comes at a significant cost.  As the below official CMS declaration states, agencies that decide not to submit may receive post-payment reviews.  In other words, the MAC may request an ADR on every claim that is not submitted through RCD.


The benefits of participating in RCD is that you not be subject by an ADR from your MAC for any claims that are affirmed.  The affirmation process ensures that each claim meets the Medicare beneficiary requirements, e.g. F2F, medical necessity, need for skilled services, homebound, short term and intermittent care, etc.  The documentation reviewed during this affirmation process consist of the OASIS, Plan of Care, F2F and supporting documentation.   An ADR will consist of these in addition to every order, visit note, additional OASIS assessments, etc.   Thus choosing to participate provides significant protection to an agency retaining their claim payment as opposed to the risk of extra scrutiny posed by an ADR and eliminates the significant amount of time an agency spends in preparing every claim for an ADR.


Agencies that choose to participate in the RCD will need to make their cycle 2 choice between April 1 – April 15.  These choices will take effect May 1.


Due to the continuing public health emergency, CMS will continue the phased-in participation of the Review Choice Demonstration for Home Health Agencies in Florida and North Carolina for an additional 90 days. Providers interested in participating should make their Cycle 2 Choice selections between April 1, 2021 and April 15, 2021.  Cycle 2 will begin on May 1, 2021 for those providers.

  • Providers may choose from a subsequent choice selection based upon their Cycle 1 results.
  • Providers that do not make a choice selection may continue submitting pre-claim review requests.
  • Claims that go through pre-claim review and are submitted with a valid UTN will be excluded from further medical review.
  • Claims submitted without going through the pre-claim review process will process as normal and will not be subject to a 25% payment reduction. These claims may be subject to post payment review in the future through the normal medical review process.
  • Providers do not need to take any further action if they choose not to participate


Regardless of the choice your agency makes, HealthCare Synergy has managed services that can assist you between our coding, OASIS review, full chart review, ADR reviews, or billing services.  Our clinicians have the training and experience to assist you in reviewing the documentation and identifying risks your charts pose.