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NOA FAQs

Click to find answers to frequently asked questions on the 2022 home health Medicare billing changes.

What is a Notice of Admission (NOA)?

A Notice of Admission (NOA) is a one-time submission that establishes the home health plan of care (POC) and covers contiguous 30-day POCs until the patient is discharged from Medicare home health services. This new process will eliminate the need for any type of RAP. NOA submission is required at the start of care only, and untimely submission of NOAs will result in a daily penalty equal to 1/30th of the total reimbursement for every day that the NOA is not submitted. There are no requirements for any additional information at any other point in the 60-day episode. For all patients who are on service on January 1, 2022, organizations will need to submit a one-time NOA at the start of their first 30-day period in 2022. An NOA for patients admitted prior to January 1, 2022, helps the organization establish a new “admission” date within the Common Working File (CWF) without requiring an actual discharge or readmission on the part of the provider.

What is the purpose of the NOA?

The NOA establishes that the patient’s care is to be provided by the submitting organization and remains active until a discharge is submitted for the patient. However, once a discharge is submitted to Medicare, the home health organization must submit a new NOA to send and receive payment for any additional claims.

When do NOAs begin?

The Notice of Admission requirements will begin on January 1, 2022.

Is the NOA related to PDGM?

Yes. The NOA is part of the final phase of PDGM, which began in 2019 and followed an evolution transitioning from 60% of the anticipated payment upfront to 20% in 2020, to upfront payments being completely phased out in 2021 with the no-pay RAP. NOA submission is a new process that will replace the RAP submission process.

If Medicare is not the primary payer, should an NOA still be submitted?

Yes. Even if Medicare is not the patient’s primary insurance payer, submitting an NOA is recommended. Submitting an NOA for these patients ensures that one is on file with Medicare in case the payer changes. The NOA will establish care with Medicare so that the final claim can be released. It is important for an organization’s revenue cycle management team to review the billing and claim requirements of each managed care payer to ensure proper and timely claim submission and to minimize denials.

Will Medicare Advantage plans require an NOA?

Billing and documentation requirements vary by Medicare Advantage plan. It is recommended that organizations contact their contracted Medicare Advantage plans and inquire about changes in 2022 that may include the NOA.

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 NOAs. These preferences can be modified to fit the payer’s effective date, should their onset differ from the CMS date of January 1, 2022. For additional information on this functionality, click here.

How long do we have to transmit an NOA?

Home health organizations must submit an NOA to their Medicare Administrative Contractor (MAC) within five calendar days from the start of care date.

What are the penalties for late submission of an NOA?

For every day after the five-day period that the NOA is not submitted, the organization will be penalized 1/30th of the final payment until an NOA is submitted. This payment reduction also applies to outlier payments.

How many NOAs is a patient required to have on file with CMS?

The Centers for Medicare and Medicaid Services (CMS) only requires one NOA for any series of home health plans of care beginning with admission to home care and ending with discharge. After a discharge is reported to Medicare, you must send a new NOA before you submit any additional claims.

Do I need to continue submitting RAPs?

RAPs are no longer required for 30-day benefit periods beginning on or after January 1, 2022.

Do I need to submit an NOA for patients already receiving service prior to January 1, 2022?

Yes. An NOA is required for all existing patients whose services will continue in 2022. You should submit an NOA with a one-time, artificial “admission” date corresponding to the “from” date of the first payment period of continuing care in 2022.

How will transition episodes spanning 2021 to 2022 be handled in Axxess Home Health?

All NOAs with billing period start dates on or after January 1, 2022, will follow the new requirements 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 the required go-live dates.

How do you set a start date for the initial visit for patients continuing care in 2022?

All patients receiving care in 2021 who will continue receiving care in 2022 will need an NOA for the first period of continuing care in 2022. The organization will need to set an artificial start date for the first initial visit. That artificial admission date will remain the same for all subsequent episodes until the patient is discharged. For example, if a period of care begins December 13, 2021, and ends January 11, 2022, the NOA for the next 30-day period is submitted with the admission date of January 12, 2022.

If a patient is discharged and readmitted for services, will a new NOA be required?

Yes. Once a patient is discharged, their NOA is no longer valid. If the same patient is admitted for services again, a new NOA is required.

Can an organization request an exception for an NOA submitted outside the five-calendar day window?

Yes. There are four circumstances that may qualify:


1. Fires, floods, earthquakes or other unusual events that inflict extensive damage to the organization’s ability to operate.

 

2. An event that produces a data filing problem due to a CMS or MAC system issue that is beyond your control.

 

3. You are a newly Medicare-certified organization that is notified of certification after the Medicare certification date or that is awaiting its user ID from its MAC.

 

4. Other circumstances that CMS or your organization’s MAC determines are beyond your control.

 

What is required prior to submitting an NOA?

Before submitting an NOA, you must have a verbal or written order from the physician that contains the services required for the initial visit and you must have conducted an initial visit at the start of care.

Does an OASIS need to be completed to bill an NOA?

No. An OASIS assessment does not need to be completed to bill an NOA.

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

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

Does a visit need to be completed to bill an NOA?

CMS has clarified that an initial visit is required for initial NOA submission, meaning a billable start of care visit must be completed. However, for current patients’ NOA submissions, organizations can use the start date of the billing period to serve as the service line date to submit the NOA.

What is the type of bill (TOB) used to submit an NOA?

You will submit NOAs using TOB 32A. Then you will use TOB 329 for all claims following submission of the NOA. The National Uniform Billing Committee (NUBC) has redefined TOB 329 to represent an original claim, rather than final claim, for all claims with “from” dates on or after January 1, 2022. 32D is used for cancellation of admission. Reduction amounts will be displayed with a value code of “QF” on the claim.

How can my organization submit the NOA at the onset of the episode in Axxess Home Health?

Beginning January 1, 2022, the Billing Center in Axxess Home Health will enable users to bill NOAs at the onset of the appropriate billing period. For additional information, click here.

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

No. The NOA only needs to contain a primary diagnosis, which can be generic.

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 NOA does not need to match the final claim. If the diagnoses change, no further action from the organization is required.

Can I submit an NOA with a generic HIPPS code?

Yes. A generic HIPPS code can be used to submit an NOA if the OASIS assessment is not available.

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

No. A HIPPS code is not required for NOA submission. However, Axxess Home Health will submit NOAs with the generic HIPPS code 1AA11 until further clarification is received from CMS.

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

No. All claims in 2021 and beyond 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 NOA and will not be used for reporting purposes in Axxess Home Health.

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

Yes. The Billing Center in Axxess Home Health includes a RAP/NOA Aging column that enables users to filter results by age for interactive, hands-on management of internal processes. This tool displays the ages of NOAs that have not yet been submitted. The green portion represents NOAs that are 0-2 days old. The orange represents NOAs in their third or fourth day. The red portion shows NOAs that are five or more days old. Clicking on any portion of the bar will filter the results for those patients. Additional reporting measures like a Billing Dashboard and Administrative Dashboard are being developed to further assist organizations with managing and reviewing NOA and final claim submissions.

Where can I find more information and resources on the 2022 billing and NOA regulatory updates?

Centers for Medicare and Medicaid Services NOA Companion Guide

Office of the Federal Register, Current Public Inspection Issues

Centers for Medicare and Medicaid Services, Final Rule, 9 November 2021

CMS Manual System, Pub 100-04 Medicare Claims Processing, 9 June 2021

MLN Matters, Replacing Home Health Requests for Anticipated Payment (RAPs) with a Notice of Admission (NOA) – Manual Instructions, 9 June 2021

Centers for Medicare and Medicaid Services, Medicare Administrative Contractors Page

CGS, The New 2022 Home Health Notice of Admission (NOA), 28 September 2021