In 2016, CMS began rolling out a pilot program to enforce a more proactive oversight strategy on Medicare home health claims in an effort to reduce fraud and waste. The ultimate goal was to reduce improper payments and the cost of additional documentation and resources it takes for CMS to chase them. This “Pre-Claim Review” demonstration subjected home health agencies to additional billing scrutiny and red tape.
There was a lot about the demonstration home health agencies disliked. After a rocky start in Illinois, industry organizations and leaders strongly voiced their opposition to Pre-Claim Review, prompting lawmakers to push for a delay in Florida implementation. CMS then announced an indefinite delay to evaluate the program. During this pause, home health agencies in Illinois were able return to normal claims submission while CMS worked to revise the demonstration.
In May, CMS announced a pubic comment period in the Federal Register on a second version of Pre-Claim Review called “Review Choice Demonstration” (RCD).
Here’s what we know about RCD so far:
- Public input is open through July 30, 2018 and people can submit their comments electronically or by mail.
- The new proposal offers home health agencies three options:
- Pre-claim review – Home health providers must submit pre-claim documentation on all claims.
- Post-payment review – A new option for providers, this allows home health agencies to submit their claims for review after receiving payment.
- Opt out – Facilities can completely opt out of pre-claim and post-payment review, but will take a 25% reduction on all Medicare claim payments and make them eligible for review by Recovery Audit Contractors.
- Once a provider has reached a target approval rate, it can be relieved from RCD except for spot checks to ensure continued compliance.
- RCD is expected start in Illinois and expand to Ohio, North Carolina, Florida, and Texas with the possibility of continued expansion to other states in the Palmetto/JM jurisdiction.
- The new demonstration will start no sooner than October 1, 2018.
We will continue to monitor the developments on this new proposal and update you with new information. Should CMS plan to implement RCD, eSolutions will reinstate its Pre-Claim Review product as a revamped RCD tool.
Billing Medicare is complex. Simplify the rules and regulations with your free guide to getting started with home health billing!
**Update – August 6, 2018: The public input period has ended, and CMS only received 470 public comments during the 60-day feedback window. The vast majority of comments were against the RCD program. Home Health Care News reports that the industry is divided on the severity of RCD and its impact.
**Update – October 9, 2018: CMS hopes to launch RCD in Illinois on December 10, 2018. CMS also announced that it will expand the public commenting opportunity for the demonstration to October 29th.
**Update – November 16, 2018: Home health agencies will make their review choice through the Palmetto GBA eServices online provider portal.
**Update – December 12, 2018: RCD did not launch in Illinois on December 10th. Providers are still waiting for CMS to open the RCD portal so they can make their choice between pre-claim review, post-payment review, or a limited review with a 25% payment reduction.
To stay up-to-date on RCD and many other reimbursement hurdles, be sure to subscribe to posts from our Home Health & Hospice Resource Center.