2020 was a difficult year for many home health agencies. 2021 proves to be even more complicated with the introduction of the no-pay RAP. Let’s take a look at the no-pay RAP penalties and expert tips on how to avoid them.
No-Pay RAP Penalties
Your agency is subject to a penalty if you don’t submit your no-pay RAPs in a timely manner. For a 60-day certification period, you must submit a RAP for the first 30-day period within five calendar days from the start of care date. In addition, for the second 30-day period, you must submit the RAP within five calendar days of the “from date.” If you don’t submit within five calendar days, the penalty is equal to a 3% reduction in the wage and case-mix adjusted 30-day payment amount for each day from the start of care/admission date until the RAP submission date.
While on the surface a 3% penalty doesn’t sound terrible, it can quickly turn into 20% when your submissions are delayed. Keep in mind that while you have five days to submit the RAP, the penalty for not doing so begins on the first day of the 30-day period, NOT the first day after you miss the deadline.
Timing is Critical
CMS states that, “A timely-filed RAP is submitted to the A/B MAC (HHH) and accepted by the MAC within five calendar days after the ‘From the date’ of a HH period of care.” This means that not only does your RAP need to be submitted within the five days, your MAC must accept it as valid without error.
If you haven’t already, establish a process that ensures your RAPs are accurate and are submitted within five calendar days after the start of each 30-day period of care. Once the order and first visit are complete, submit the RAP. An OASIS assessment and established plan of care aren’t required. Be sure to reach out to your Medicare Advantage providers to establish understanding of your contract. Find out if they require anything special regarding the timing of submissions.
Examine Your Revenue Status
For the past year, you’ve had to adjust to smaller split percentage payments. But in 2021, the split percentage is gone. You need to closely manage the impact no-pay RAPs can have on your cash flow. For example, do you have cash reserves to fill in the gaps?
Don’t fall victim to the “slow fade” where your collections go stale or disappear after 90 days. You may not even notice there’s a problem for a few months. Eliminate your billing backlog and write-offs. Now more than ever, you’ll want to be sure to collect everything you’re owed. Don’t have the time or staff to manage collections? Revenue cycle management companies, like HealthRev Partners, offer home health billing and home health billing recovery services.
Coding and Billing Staff Preparation
Is your coding and billing team burdened with managing the short RAP turnaround time? If you’re not able to bill due to time constraints, you should consider outsourcing to a third-party RCM partner immediately. The money that you’ll save through accurate, timely claims submission will more than make up for the dollars spent.
Vendor Partnership Readiness
Did your EMR vendor offer updates to help you meet the no-pay RAP requirements? Did they provide the training your staff needed for success? Is submitting RAPs easy using your EMR? If you work with a coding and billing services vendor, are they submitting your RAPs on time and error-free? Talk with them about how they’re doing and keep a close eye on any bumps in the road.
Know CMS Requirements
There are a number of requirements that you’ll need to meet for successful submissions to avoid no-pay RAP penalties. This includes:
- The appropriate physician’s written or verbal order that sets out the services required for the initial visit must be received and documented, the initial visit for the 60-day certification period must be completed, and the individual must be admitted to home health care prior to submitting the RAP.
- You don’t need to complete the OASIS prior to submitting the RAP.
- Only the primary diagnosis code is required and this diagnosis code doesn’t need to be accurate or match the primary diagnosis on the OASIS.
- The RAPs for the first and second billing period can be submitted simultaneously at the beginning of the 60-day episode.
- You don’t have to have a first billable visit for the second RAP or for recertification.
- The HIPPS codes on the RAP and the final claim must match. The actual HIPPS codes and reimbursement will be determined by the information submitted with the final claim. Be sure you have a system in place to ensure accuracy.
Time is of the essence to avoid no-pay RAP penalties. You must make sure that you have a good handle on your revenue cycle operations and workflows. If you’re struggling now, then it’s not going to get any better. Make use of available technology and seek out assistance from a revenue cycle management partner if you’re feeling overwhelmed.
How HealthRev Partners Can Help
We’re passionate about securing the success of home health and hospice agencies nationwide. We’d love to consult with you about your coding and billing challenges, needs, and objectives. If you’re worried about no-pay RAP penalties, let’s talk. We can help get you on a path to success in no time.