Updated on 08/27/2021

CMS Revises Review Choice Demonstration for North Carolina and Florida

The Centers for Medicare & Medicaid Services announced Thursday, August 26, it is modifying the Review Choice Demonstration (RCD) in Florida and North Carolina, so that only those claims with dates of service beginning on and after September 1, 2021 will be subject to additional development request (ADR)/prepayment review if they are submitted without a Unique Tracking Number (UTN)/pre-claim review decision.

After CMS announced earlier this month (see NAHC Report) that effective September 1, 2021, full implementation of RCD would begin for home health providers in Florida and North Carolina, NAHC raised concerns about the policy with the agency and began advocating for CMS to revise their implementation plans to alleviate these concerns.

Specifically, as part of the full implementation, claims with dates of service on or after August 31, 2020, that are submitted on or after September 1, 2021 without a pre-claim review decision on file were to be pulled for pre-payment review and subject to the 25% reduction.

Following outreach by NAHC and the Home Care Association of Florida and the Association for Home & Hospice Care of North Carolina, CMS announced that the 25 percent reduction would not be applied for a period of 90 days from the full implementation date of RCD in NC and FL. A recording of the August 4 webinar where this was announced can be accessed here.

However, NAHC remained concerned because all billing periods would still be subject to the requirements of the review choice selected. This would include any billing periods that had not yet been submitted as of September 1, 2021, with a date of service on or after the start of the demonstration in North Carolina and Florida (August 31, 2020).

Therefore, NAHC went back to CMS because the pressures of the COVID-19 public health emergency that led to the phased in implementation and transition policy have not eased. In fact, in some places, the COVID-related pressure has, if anything increased. To require HHAs that wish to use pre-claim review to submit both the claims that involve starts of billing periods prior to September 1 along with those that start September 1 and later more than doubles the workload in the near term.  If HHAs try to space out those two claims groups to mitigate the workload concerns, cash flow problems could be triggered.  Also, providers have had the understanding, based on communication at the onset of the phased in implementation of RCD in NC and FL, that the transition would not implicate services that were started prior to the trigger date of full RCD.

NAHC welcomes the CMS announcement that it is modifying FL and NC implementation plans such that only those claims with dates of service beginning on and after September 1, 2021 will be subject to ADR/prepayment review if they are submitted without a UTN/pre-claim review decision. We are pleased CMS heard the concerns expressed and made this change.

As of this writing, the CMS RCD website has not yet been updated with this information, but we anticipate that change very soon.

Article published by NAHC on August 27, 2021
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