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Four Tips to Survive the No-Pay RAP

The coronavirus pandemic did not stop the Centers for Medicare and Medicaid Services (CMS) from making substantial billing changes for home health providers, including the Request for Anticipated Payment (RAP), cash upfront per Medicare patient, morphing into a no-pay RAP in 2021.

This elimination is consistent with a trend from Medicare. The start of the Patient-Driven Groupings Model (PDGM) in 2020 saw an upfront RAP payment of 60% reduce by two-thirds, to 20%.

Clinicians need to know their role in this new rule to maintain the health of their organization (and their patients).

Four Tips Clinicians Need to Know

Clinicians must understand how the no-pay RAP process works, as their decisions directly impact their organization’s revenue. This applies to nurses as well as therapists, as therapists can now perform Start of Care (SOC) assessments.

Documentation will be the key to an organization’s success with the no-pay RAP.

  1. Understand Internal Policies: Organizations are adapting their internal policies based on these new rules. Staying knowledgeable about company-wide mandates is paramount to a clinician’s success within an organization.
  2. Ensure Timely Submission of Billable Visits: A billable visit must be submitted within the first five days of the SOC. Since the SOC is considered day zero, there are technically six days from when the patient is admitted to when the first billable visit is due.
  3. Submit Documentation by Day Three: Although the organization has five days to submit a billable visit, this visit must also be approved by CMS within the Common Working File (CWF) during that time frame. In order to meet that tight deadline, clinicians should aim to complete and submit documentation within three days.
  4. Have a Complete Physician Order: Clinicians must include a verbal order from a physician. However, the physician order must contain all services that are required during the first 30-day billing period, including the first billable visit.

What Is Considered a Billable Visit?

It seems self-explanatory, but it’s very common for clinicians to document billable visits incorrectly.

A billable visit can be many types of visits, which can lead to confusion, but it’s simply a skilled nursing visit, such as wound care, therapy, instructing the patient on medications, teaching the diagnosis process, etc. The written physician order must be specific to the skilled nursing or therapy visit required.

For instance, the Outcome and Assessment Information Set (OASIS) can be completed within the initial five days of care as a billable visit. However, if it’s completed on a second visit, it’s up to the clinician to ensure a second billable visit is clearly marked on the physician orders.

Success Begins with Accurate and Timely Documentation

Clinicians need to focus on documenting and submitting the first billable visit within three days of the SOC. The easiest and most efficient way to meet this requirement is to perform point-of-care documentation using a home health software.

Some organizations still document on paper, a method that adds unnecessary time, as documentation is submitted electronically. In a process where time equals money, investing in an intuitive home health software makes the most financial sense.

For answers to more of clinicians’ home health billing questions, watch From Start of Care to Final Claim: 2021 Changes Home Health Clinicians Need to Know, a popular Axxess LinkedIn Live.

Axxess Home Health is a cloud-based home health software that supports documentation at the point of care on any device. Axxess provides up-to-date billing resources for home health organizations to stay compliant and successful.


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