no-pay rap questions

As we wrap up the first quarter of 2021, Medicare Administrative Contractors (MAC) have fielded several no-pay RAP questions regarding processes, requirements, and penalties. 

Here are some of the most frequently asked questions and their answers: 

Q: Are HIPPS codes still required on RAPs? If yes, do the HIPPS codes need to match on the RAP and final claim? 

A: Yes, HIPPS codes are still required on RAPs and a home health agency may submit any valid HIPPs code. You may submit the HIPPS code you expect to use for payment, or you can submit any valid HIPPS code. 

For the final claim, the 0023-revenue code line should include the HIPPS code that was on the RAP. The first four positions of the code must be identical to the value reported on the RAP. This allows the system to match the claim with the corresponding RAP. 

Q: Do all diagnoses have to be reported on the RAP and the period of care claim? 

A: You must submit the principal diagnosis code on the RAP. Other codes are optional. You should report the principal and other diagnosis codes on the claim, as they’ll be used for payment grouping. The claim and OASIS diagnosis codes will no longer be expected to match. 

Q: Does the submission within five days of the “From” date include weekends and holidays? 

A: Yes, there will be a non-timely submission payment reduction when the RAP is not submitted within five calendar days of the “From” date of the RAP. The “From” date is day zero. Count five calendar days (NOT business days) starting the day after the “From” date to determine timely submission. 

Q: Does the RAP only need to be submitted within five calendar days of the “From date” to meet the requirement? 

A: No. The RAP must be submitted AND accepted by the MAC within five calendar days. 

Q: When claims are submitted after hours, the 277CA is not returned until the next day. There’s concern about non-timely payment reduction when a RAP needs corrected. Will this process change? 

A: No. You should take this into consideration when calculating timely submissions of the RAP. 

Q: Can an agency appeal a late RAP penalty? 

A: No. Appeals are only requested on denied claims. An agency can request an exception on the final claim if it meets one or more of four qualifying circumstances.  

Q: Do LUPAS require a RAP? 

A: No, LUPAS do not require a RAP. However, if a RAP is filed for a LUPA, it must be filed timely. 

Q: If an error is discovered on the RAP, does the home health agency have to wait until its returned to correct and resubmit? 

A: No. When a RAP is set to returnthe agency can submit a new, corrected RAP to avoid or reduce the penalty. The new RAP will not edit as a duplicate since the initial RAP did not process. 

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