Ohio has Made Its RCD Choices (Sort of)

The RCD choice selection period for home health agencies in Ohio with Palmetto GBA as their Medicare Administrative Contractor (MAC) ended on September 15, 2019.  All eligible agencies must have made their choice, or else will be assigned the Initial Option default of Choice 2 (100% postpayment review).  Let’s learn more about the Ohio RCD choices made.

Palmetto GBA has posted the results of choice selections made by Ohio agencies here.  The Preliminary Round 1 Selection Data is:

Choices made:

  1. (100% Pre-claim review): 84% of agencies
  2. (100% Postpayment review): 14%
  3. (Minimal review): 2%

A QIRT Expert’s Take on Ohio RCD choices:

“Given the pros and cons of each Choice option, it is a surprise that even 14% of agencies chose the 100% postpayment review of their records,” said Joe Osentoski, Reimbursement, Recovery and Appeals Director at QIRT.  “This is the equivalent of a 100% ADR review — and remember, it will be conducted after service has been provided.”

Further, another surprise is that any providers opted for Choice 3. This choice is essentially swapping no review of claims for a 25% reduction on payment and the possibility of Recovery Audit Contract (RAC) activity. When Illinois providers made this choice initially, Palmetto GBA contacted each agency to review their choice. Ultimately, further clarification resulted in every one of those agencies selecting a different RCD selection. In stark contrast, 2% of Ohio agencies are sticking to this decision for the duration of the RCD 5-year period. 

While the overall percentage of agencies making each choice is interesting, the Palmetto GBA information does not state the actual number of Ohio agencies that made each selection. Adding those to the results of the selections adds some key information: not every agency chose.

Choices:

  1. (100% Pre-claim review): 84% (385 agencies)
  2. (100% Postpayment review): 14% (65 agencies)
  3. (Minimal review): 2% (7 agencies)

Wait – how many agencies are in Ohio?

Right, the numbers aren’t adding up. A takeaway/concern with this information is that only 457 Ohio home health agencies made a selection via Palmetto GBA eServices for an RCD choice. This is out of 667 agencies that were eligible to make a choice and are not included in the numbers above: this difference is 210 agencies (31% of eligible agencies). Adding in these recasts the Ohio choice selection percentages as:

  1. (100% Pre-claim review): 58% (385 agencies)
  2. (100% Postpayment review): 41% (275 agencies)
  3. (Minimal review): <1% (7 agencies)

What will RCD look like in Ohio when it starts?

It will look challenging. That over 200 Ohio agencies have apparently defaulted into Choice 2 and will be on 100% claim ADR review starting September 30 will put a significant administrative and cash-flow burden on these agencies. Even if these agencies are timely in submitting the ADRs and getting them paid, the payments will not be timely and the added work will be substantial.   

Ohio RCD choices have been made, the demonstration will begin in Ohio on September 30, 2019, and all episodes of care—NOT just starts of care–starting on or after this date will be subject to the requirements of the choice selected. 

69% of Ohio agencies have made their choices: 100% have to live with them under RCD. 

QIRT can help.

If you are feeling overwhelmed, reach out for assistance in assessing current status and needs to address before RCD goes live in your state. QIRT experts will help.

1. Do-It-Yourself:

  • Readiness Tool Kit– Prepare for Review Choice Demonstration (RCD) with this advanced tool kit that includes everything an agency needs to complete an RCD Self-Audit: the Agency Guide to Success, plus a survey instrument – the RCD Questionnaire.
  • Analyze your current workflow processes and determine how to adjust for more efficiency and cost-effectiveness. Critical: understand if your current patient charts are complete and contain all the documentation and data required to ensure claims submitted are supported.
  • The added bonus? Prep for RCD now means an easier transition to PDGM later.

2. QIRT Expert Help

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