RCD in Ohio Creeps Closer

Ohio will begin Review Choice Demonstration (RCD) on September 30, 2019. For Ohio agencies, this development has created greater urgency for information. On August 7, Palmetto GBA held their first RCD teleconference since the RCD in Ohio announcement. These teleconferences occur monthly and give a current status of RCD in general and usually offer extensive time for questions. They are open to all providers and interested parties. The next one is set for September 4, 2019, at the new time of 11:00 am EST.

What Did We Learn?

In case you missed it, items of interest from the August teleconference include:

  • The Ohio selection period is open now and runs from August 16 to September 15. The selection must be done via Palmetto GBA eServices.
  • Palmetto GBA will call every Ohio provider who is not registered for eServices.
  • Beneficiaries and physicians in Ohio will receive letters informing them of the start of RCD in the state.
  • There is no Illinois affirmation rate information to share (from their June 1 RCD re-start).
  • There is no further information regarding how RCD will interact with the pending Patient-Driven Grouper Model (PDGM) revision next year.
  • Under RCD, if services are not initially on the claim but are added during the episode, a new pre-claim review does not need to be submitted. (This situation will only apply to those in Choice 1: Pre-Claim Review since other options will be reviewed via Additional Development Requests [ADRs].)
  • Reminder: Medicare Advantage claims will not be subject to RCD (any Choice).
  • Sites under Targeted Probe & Educate (TPE) reviews will have their current probe completed and further TPE activity will cease once RCD starts (September 30 for Ohio – already in effect for Illinois).
  • While Low Utilization Payment Adjustment (LUPA) claims are not required to be submitted for Pre-Claim review, it is recommended to submit all agency claims via this process in case the claim later changes from LUPA status. Otherwise, the pre-claim submission would need to be done to obtain a Unique Tracking Number (UTN) prior to final bill submission to avoid a payment reduction.
  • If the payer changes (for example: Medicare Advantage to Medicare PPS) during the period, a pre-claim submission should be completed if able to do so timely.

Which State Will Be RCD’d Next?

The order and specific timing of the remaining states to start RCD (Texas, Florida, North Carolina) is still not provided: just that at least 60 days’ notice will be given before starting RCD in each of those states. Whether these 60 days will be after RCD begins in Ohio is unclear. Therefore, the spacing and timing for the remainder of the states to start RCD is unknown.

Let’s Recap.

The RCD choice selection period for home health agencies located in Ohio has begun and will run from August 16, 2019, to September 15, 2019.  Home health agencies should visit the Palmetto GBA provider portal here for information and instructions on the selection process: the choice selection must be made via the portal. Palmetto GBA will also send letters to all Ohio home health agencies detailing this information. Ohio home health agencies that do not make a choice selection by the end of the period will be automatically placed in Choice 2: Postpayment Review (the 100% ADR review). Following the close of the choice selection period, the demonstration will begin in Ohio on September 30, 2019, and all episodes of care – not just starts of care – beginning on or after this date will be subject to the requirements of the choice selected. 

How Do I Prepare?

1. Determine which choice is best for the agency (Hint: most select Choice 1: Pre-claim Review).

2. Read the entirety of the CMS Review Choice Operational Guide.

3. Review the CMS RCD website and Palmetto GBA site for teleconferences, webinars, training material, and education opportunities.

4. Check your agency referral and admission process to assess how quickly you obtain the information needed for pre-claim and what your review process is for looking at the content of those documents. The mere presence of a physician face-to-face encounter will not be enough to ensure claim review affirmation. In relation to the chosen RCD option, examples of checked items:

  • Content of the encounter
  • Support for homebound
  • Timeliness of orders
  • Completeness of plans of care
  • Relation to home health focus of care

5. 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 can help, we are experts in this area.

QIRT can 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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