21 Aug RCD Delayed
CMS DELAYS RCD UNTIL MARCH 2020
Advocates for home health care have achieved a significant triumph regarding the ongoing struggle against implementation of RCD (Review Choice Demonstration).
After a series of sessions reviewing the matter, the Centers for Medicare & Medicaid Services (CMS) released an official statement this past Monday that the RCD will be delayed until March 2, 2020. Originally, implementation of the demonstration was slated to start in Texas on December second of 2019. This would have resulted in home health care providers in the Lone Star state being forced to simultaneously navigate RCD while also dealing with the equally intimidating PDGM (Patient-Driven Groupings Model).
As notifications were sent out from the NAHC to Homecare agencies across the state, many CEOs and managers of agencies breathed a sigh of relief. The impact of RCD’s December implementation was being dreaded by agencies large and small, particularly locally owned and operated in-home-care providers. In other states such as Illinois and Ohio, a reconfigured version of the Pre-Claim Review Demonstration (PCRD), RCD has already begun.
At its core, the demonstration’s intent is to cripple improper billing attempts by enacting the requirement that home health providers must submit Medicare claims for a comprehensive review directly by a MAC (Medicare Administrative Contractor). Statistically, the Medicare fee-for-service improper payments rate fell in 2018 (down from nearly a reported 10% in 2017).
RCD as it stands, allows multiple options for comprehensive review, inclusive of pre-claim as well as post-payment options. Home health providers also have the option of a minimal review choice, with the caveat that this option levies a 25% payment reduction upon them. Providers of homecare services that can demonstrate a proven history of billing compliance are granted additional options. Agencies that have a strong intake process and nothing to hide, will likely go with pre-claim review.
As a result of the delay, the choice selection period for home health providers in the state of Texas will start on Jan. 15, 2020 (ending on Feb. 13, 2020). After Texas’ RCD implementation, North Carolina is slated to begin as is Florida around the beginning of May. Officials at CMS announced that they will be monitoring the transitions to PDGM, making determinations if changes are needed based on what takes place.
As an aside, in their official statement, CMS also noted that with respect to PDGM, it will phase in the inclusion of Low Utilization Payment Adjustments (LUPAs) within the RCD (Review Choice Demonstration). As it stands, home health care providers are served a LUPA if they provide four or less visits within a 60-day episode of care to any category of patient. PDGM effectively takes that singular standard and embellishes it with the introduction of hundreds of different LUPA scenarios.
The delay in RCD should prove especially beneficial for helpful for smaller home health agencies that lack a large network of resources to efficiently adopt unwanted regulatory burdens. Larger agencies often have the luxury of hiring additional workers or assigning specific current employees to handle regulatory changes (which small agencies largely cannot afford).
At the NAHC annual leadership conference in Washington earlier this month, PDGM and RCD implementation was the hot topic among officials and organizational leaders/workers in the home health industry. The president of NAHC stated that he believed that CMS underestimated the burdens associated with PDGM, citing a lack of understanding of the actual workload and timing of the endeavor.
Regardless of the short-term victory in Texas, home health providers should have RCD on their radar as 2020 approaches. Officials cite that there are no indications that CMS will start slowing down on their permanent implementation goals.
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