Let’s discuss the RCD implementation delay.
The Review Choice Demonstration (RCD) for Home Health Services was scheduled to begin in Illinois on December 10, 2018. Numerous CMS webinars, Palmetto GBA webinars, and a CMS Open Door Forum all said so. However, that date seems to be a mirage, at least for the present time.
Due to awaiting Office of Management and Budget (OMB) approval to proceed, the restart of pre-claim review and the addition of other choices did not meet that date. Additionally, there is no firm statement to when it will commence. This demonstration will now offer Illinois home health agencies three choices at two different time points to have their records scrutinized for proper payment and to meet Medicare eligibility and coverage requirements.
In addition to the 100% pre-claim review option, agencies may also choose:
- 100% postpayment option—essentially putting themselves on a 100% Additional Development Request (ADR) review
- OR agencies can opt to not send any claims for pre-claim or postpayment review and suffer an automatic 25% payment reduction.
Illinois agencies who achieved a high affirmation rate under pre-claim review can select from three subsequent choices:
- 100% pre-claim review
- A statistically valid random sample (SVRS)
- 5% ADR spot check.
Palmetto GBA has now indicated that they will send letters to Illinois agencies informing them of their options, but this will also be available on the RCD portion of their website. Thus when RCD starts, agencies will not have to wait for their letter to make a selection. On the website, only the available choices will be listed for an agency to select how they wish to participate in RCD.
Agencies are smart to assess their current claims in light of what RCD will look at to better gauge which choice they will make once the implementation date for RCD is given. Recent Targeted Probe and Educate results posted by Palmetto GBA showed the physician face-to-face encounter issues remained the top reason for claim denials, and this would pose a problem for any home health agency in RCD.
Looking at the needs of RCD in an organized, objective manner is a key to successfully managing this disruption to the normal flow of business.
To successfully negotiate this demonstration, track processes from:
- The receipt of the referral to
- Face-to-face encounter documentation to
- Plan of care generation to
- OASIS assessment completion to
- Certification documentation.
So while the date of implementation is not yet set, the way forward is clear: preparing for RCD is the key to success so it’s not a rush to comply when it is implemented.
Prepare for RCD
- Preparation is key.
- Get out ahead of the changes and alleviate some pressure.
- Consider outsourcing part of your process.
QIRT is prepared to support your agency via readiness audits, checklists, and a team of experts. Find out more.
By Joe Osentoski, BAS, RN-BC, QIRT Reimbursement Recovery and Appeals Director
Questions? Ask our experts: Compliance@QIRT.com