Starting January 1, 2022, Medicare will require Home Health Agencies to submit a one-time Notice of Admission (NOA) instead of Request for anticipated Payment (RAP). Medicare has been phasing out RAP payments for the last two years. The NOA is a one-time submission that establishes the HH POC and covers 30-day payment periods until the patient is discharged.
CMS introduced the Patient-Driven Grouping Model (PDGM) payment model for Home Health Prospective Payment System (HH PPS) starting January 1, 2020. For the first year, Medicare continued to make RAP payments for each payment period. For the second year (2021), Medicare introduced the No-Pay RAP policy. Under this policy, Home Health Agencies were still required to submit a RAP even though Medicare did not pay RAP. The third step is replacing the RAP with NOA, which will start on January 1, 2022.
CareVoyant will be implementing software enhancements to accommodate Notice of Admission (NOA) to help Home Healthcare Agencies effectively manage the transition to NOA.
Notice of Admission:
CMS has established the following criteria for submitting NOA beginning January 1, 2022.
The appropriate physician’s written or verbal order that sets out the services required for the initial visit has been received and documented.
The initial visit within the 60-day certification period was made, and the patient was admitted to home health care.
For all patients receiving HH services in 2021 whose services will continue in 2022, the agency should submit a one-time NOA with a one-time, artificial “admission” date corresponding to the “From” date of the first period of continuing care in 2022.
For all patients starting HH services in 2022, the agency should submit a one-time NOA beginning with admission.
Additionally, for CY 2022, CMS established a non-timely submission payment penalty when the HHA does not submit the NOA within five calendar days from the start of care for the first 30-day period of care in a 60-day certification period.
This reduction in payment will be equal to a 1/30th decrease to the wage and case-mix adjusted 30-day period payment amount for each day from the home health “from date” until the date the HHA submits the NOA. The penalty applies to outlier claims, and low utilization payments adjustment (LUPA) claims. For LUPA 30-day periods of care in which an HHA fails to submit a timely NOA, no LUPA per-visit payments would be made for visits that occurred on days that fall within the period of care before submitting the NOA. The payment reduction cannot exceed the total payment of the claim.
The 5-day submission time frame and the late submission penalty have caused concern for many agencies. The current requirements for submitting the NOA entail several processes that must be conducted, such as a complete plan of care that is sent to the physician, a comprehensive assessment including the OASIS to establish the POC and generate an accurate HIPPS code, and if the certification statement is included on the POC, all certification requirements are needed to be completed before submitting the NOA.
With the modified criteria, Home Health Agencies will have to have the physician order in place and the initial visit completed. There is no need to complete the OASIS and Plan of Care before sending NOA.
Home Health Agencies will need to modify agency operations and the electronic health record (EHR) to accommodate the revised PDGM criteria in 2022. The main goal for agencies should be the timely submission of NOA without incurring a late submission penalty.
Software platforms will have to be adjusted to accommodate the new PDGM billing process. The following are some of the requirements.
The NOA claim process should be adjusted to submit the NOA with the new criteria and the correct Bill Type (32A).
The software should automatically identify continuing episodes from 2021 and select the correct NOA date for the NOA claim.
Provide alerts about the status of the NOA and enough information to make sure NOA will be sent within five days.
Provide an option to create late NOA adjustments during the final bill automatically.
CareVoyant NOA Enhancements
CareVoyant Enhancements for NOA
CareVoyant will be implementing the following software enhancements to help Home Healthcare Agencies to stay efficient and compliant with the new PDGM changes.
NOA Claim Process: CareVoyant will adjust the NOA claim process to process NOA claims once the initial order is in place and the first visit is completed. CareVoyant will automatically select the current period to send the NOA with artificial “admission” date corresponding to the “From” date of the first period of continuing care in 2022.
PDGM Billing Manager: CareVoyant will provide alerts and key information to enable agencies to monitor and process NOA claims on time.
PDGM Monitor: CareVoyant will provide alerts and key information to monitor the status of NOA claims.
Final Claim Process: CareVoyant will automatically adjust the Final claim process for late NOA payment reduction.
ABOUT CAREVOYANT
CareVoyant is a leading provider of cloud-based integrated enterprise-scale home health care software that can support all home-based services under ONE Software, ONE Patient, and ONE Employee, making it a Single System of Record. We support all home based services, including Home Care, Private Duty Nursing, Private Duty Non-Medical, Home and Community Based Services (HCBS), Home Health, Pediatric Home Care, and Outpatient Therapy at Home.
CareVoyant functions – Intake, Authorization Management, Scheduling, Clinical with Mobile options, eMAR/eTAR, Electronic Visit Verification (EVV), Billing/AR, Secure Messaging, Notification, Reporting, and Dashboards – streamline workflow, meet regulatory requirements, improve quality of care, optimize reimbursement, improve operational efficiency and agency bottom line.
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