Click to find answers to frequently asked questions on the 2021 billing changes.

For resources and webinars on no-pay RAPs and 2021 billing, click here.

How will RAPs be impacted by the 2021 billing changes?

Beginning January 1, 2022, the Centers for Medicare and Medicaid Services (CMS) will replace Requests for Anticipated Payment (RAPs) with a Notice of Admission (NOA) that will only need to be submitted at the initiation of home healthcare services.

The phaseout of RAPs will begin on January 1, 2021. Beginning January 1, 2021, all home health organizations will no longer receive split-percentage payments.

For every day after the fifth day of the billing period that the RAP is not submitted, the organization is penalized 1/30th of the final payment. Organizations that do not submit a timely RAP will face a minimum 20% reduction in final payment.

If a claim is identified as a low-utilization payment adjustment (LUPA) and the RAP is submitted late, visits conducted prior to submission will not be reimbursed.

A KX modifier with claim remarks can be reported to Medicare Administrative Contractors (MACs) if an organization believes they qualify for an exception to the late RAP penalty. If remarks are deemed insufficient, additional documentation will be requested. Some of these exceptions can include natural disasters or data filing problems due to a CMS or MAC issue (see MM11855).

For an overview of these changes, watch the recorded webinar below.

Why is CMS making RAP changes?

The elimination of RAPs was brought about by an increase in RAP fraud schemes, according to CMS.

The phaseout approach of reducing the RAP reimbursements to 20%, then eliminating the payment entirely and, finally, with the 2022 proposed rule of replacing it with an NOA, was deemed to be the least disruptive to home health organizations’ cash flow
(see 2020 HH PPS Final Rule).

What are the next steps for home health organizations?

Continue to review intake and admission processes and prepare to make operational changes based on the new billing standards.

Consider how the elimination of initial RAP payments will impact revenue forecasts, tracking and identifying the possible financial impact of late penalties.

Begin inquiring with various payers, such as Medicare Health Maintenance Organizations (HMOs), to understand if they will be adopting this plan and the dates any changes will take effect.

To learn how to best forecast, prepare for and execute operational changes to succeed in the new 2021 Medicare environment, watch the recorded webinars below.

Does an OASIS need to be completed to bill a RAP?

No. An OASIS assessment does not need to be completed to bill a RAP.

Does a plan of care need to be sent to the physician to bill a RAP?

No. A plan of care does not need to be sent to a physician to submit a RAP.

Does a visit need to be completed to bill a RAP?

CMS has clarified that an initial visit is required for initial RAP submission, meaning a billable start of care visit must be completed. However, for recertification episodes and instances where a patient might not be seen in the first five calendar days of care, organizations can use the start date of the billing period to serve as the service line date to submit the RAP.

How can my organization bill both RAPs at the onset of the episode in Axxess Home Health?

Beginning January 4, 2021, the Billing Center in Axxess Home Health will enable users to bill both RAPs at the onset of the episode, and split-percentage payments will help organizations seamlessly comply with the upcoming billing requirements. For additional information, visit the Billing Center Updates page.

If I bill the second billing period RAP at the same time as the first, what date is used for the RAP?

The start date for the second billing period will be the date used on the service line item for submitting the RAP.

Does the RAP need to contain all diagnoses for the patient?

No. The RAP only needs to contain a primary diagnosis.

Where can I find more information on the 2021 billing regulations?

For an overview of the 2021 billing changes, watch the recorded webinar below.

To learn how to best forecast, prepare for and execute operational changes to succeed in the new 2021 Medicare environment, as well as get answers to frequently asked questions, watch the recorded webinar below.

To review the final rule updates issued by CMS on telehealth, upcoming billing changes and the delayed implementation of OASIS-E, watch the recorded webinar below.

For information on how Axxess Home Health will accommodate these changes, see the following questions and answers.

How are verbal orders received and documented in Axxess Home Health?

Verbal orders can be added to Axxess Home Health through:

  • Patient charts via preadmission notes
  • Clinical comments
  • Physician orders, which can be tracked through the Orders Management screen

Verbal orders to admit a patient should be received prior to admission. The workflow in Axxess Home Health is designed to track orders post-admission, and your Axxess account manager will partner with you to develop a process for monitoring preadmission orders. An enhancement in early 2021 will be introduced to track preadmission orders in the system.

Can I submit a no-pay RAP with a generic HIPPS code?

Yes. A generic HIPPS code can be used to submit a no-pay RAP if the OASIS assessment is not available.

Does the HIPPS code on the final claim have to match the HIPPS code on the RAP?

Yes. The HIPPS code on the final claim must match the HIPPS code on the RAP, or the final claim will be rejected. Axxess Home Health will validate the claims to verify that the final HIPPS code matches the RAP HIPPS code.

If a system-generated HIPPS code is used, will Axxess Home Health use the real HIPPS code to submit?

No. All claims in 2021 will use the generic HIPPS code 1AA11 for submission, even if the OASIS is completed. All financial reports, however, will use the OASIS-generated HIPPS code for an accurate expected payment estimate.

If a generic HIPPS code is used, how will revenue and A/R be reported?

The final claim will store and report the HIPPS/claim amount from the assessment. The generic HIPPS code will only be used to submit the RAP and final claim, and will not be used for reporting purposes.

Does Axxess Home Health provide reports to determine what RAPs are at risk for being untimely?

The Billing Center in Axxess Home Health currently includes a RAP Aging column that enables users to filter results by age for interactive, hands-on management of internal processes. Additional reporting measures like a Billing Dashboard and Administrative Dashboard are being developed to further assist organizations with managing and reviewing RAP submissions.

Will the final claim include the finalized primary and all secondary diagnosis codes?

Yes. All information collected as part of the OASIS assessment, including primary and secondary diagnoses, flow directly to the claim. According to CMS, the primary diagnosis code on the RAP does not need to match the final claim. If the diagnoses change, no further action from the organization is required.

How will transition episodes spanning 2020-2021 be handled?

All RAP claims with billing period start dates on or after January 1, 2021, will follow the new logic updates outlined by CMS. All regulatory changes in Axxess Home Health are released prior to regulatory deadlines, and intelligence built into the system automatically updates workflows based on regulation go-live dates.

Can Axxess Home Health accommodate each Medicare Advantage payer’s preferences?

Yes. Payer setup functionality provides toggles to accommodate payer preferences, such as participation in PDGM and no-pay RAPs. These preferences can be modified to fit the payer’s effective date, should their onset differ from the CMS date of January 1, 2021.