RCD and UPICs

We feel we need to expand on the topic of RCD and UPICs. There is now a start date for the Review Choice Demonstration (RCD) project in Illinois. Next comes the need to revisit how this will be implemented. To help with this, CMS has posted an “Updated April 3, 2019” version of the “Review Choice Demonstration for Home Health Services Operational Guide.”

There is considerable information in the guide that agencies can use to prepare for RCD, including some great flow charts for each choice. One item that should not be overlooked, however, is on the top of Page 6: An HHA under Unified Program Integrity Contractor (UPIC) review is not eligible for participation in this demonstration.  If an HHA is no longer under review, the HHA will need to select an initial review choice.”

This raises some questions on how this may affect other medical review activity that is occurring in an RCD state:

  1. What are the parameters of being “under [UPIC] review”?
  2. Will this only apply to the choices agencies are given during the Illinois start of RCD?
  3. Will agencies under UPIC review be made aware of this when selecting their RCD option?
  4. Just how will this be applied to agencies currently under UPIC review when they are “no longer under review”?

These questions have been put to CMS via their RCD email address, and as any of these items become clear we will update this QIRT space. In the meantime, any Illinois agencies underdoing a UPIC audit may wish to ask Palmetto GBA to ask what it means for their starting RCD in June.

QIRT

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By Joe Osentoski, BAS, RN-BC, QIRT Reimbursement Recovery and Appeals Director

Questions? Ask our experts: Compliance@QIRT.com

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