No April’s Fool: RCD is Back

After a long wait, CMS announced yesterday that the Review Choice Demonstration (RCD) project will begin in Illinois on June 1, 2019. The order and timing of any further states to start RCD (Texas, Florida, North Carolina, Ohio) is still not provided.

As a revamped version of the prior Pre-Claim Review Demonstration, RCD will now offer three choices at two different time points to Illinois home health agencies. Following the choice period, agencies will have their records scrutinized for proper payment and meeting Medicare eligibility and coverage requirements.

The first set of choices:

In addition to the 100% pre-claim review option, agencies may also choose:

  1. A 100% postpayment option: essentially putting themselves on a 100% Additional Development Request (ADR) review
  2. Opt to not send any claims for pre-claim or postpayment review and suffer an automatic 25% payment reduction.

The second set of choices:

Illinois agencies who achieved a high affirmation rate under pre-claim review can select from three subsequent choices:

  1. 100% pre-claim review
  2. A statistically valid random sample (SVRS)
  3. 5% ADR spot check.

Palmetto GBA has indicated that they will send letters to all Illinois agencies informing them of their options. This will also be available on the RCD portion of their website. Using Palmetto’s eServices, agencies will not have to wait for their letter to make a selection. Most importantly, Palmetto has stressed that agencies can only make their selection via eServices.

Let’s recap:

The RCD choice selection period for home health agencies (HHAs) located in Illinois will begin April 17, 2019 and end May 16, 2019. Agencies should visit the Palmetto GBA provider portal for information and instructions on the selection process. Beginning April 17, HHAs will be able to view their available choices and make their selection through the portal. Palmetto GBA will send letters to all Illinois agencies detailing this information. However, you do not need to wait to receive your letter. HHAs may go to the provider portal starting on April 17.

If your agency does not make a choice selection by May 16, you will be automatically placed in Choice 2: Postpayment Review. After the close of the choice selection period, the demonstration will begin in Illinois on June 1, 2019. At that time, all episodes of care starting on or after this date will be subject to the requirements of the choice selected.

Actions to take now to prepare for RCD:

  1. Stop for a moment and take a deep breath.
  2. Determine which choice is best for the agency (most will appropriately select Choice 1: Pre-claim review).
  3. Look at the agency referral-to-admission process to determine if key information is being obtained so it can be included with pre-claim submissions (or is present in the record in case Choice 1 is not selected). These include:
    • Referral
    • Face-to-face encounter documentation
    • Plan of care generation,
    • OASIS assessment completion
    • Certification documentation.
  4. Look at staffing in the agency to match up with the tasks that will be needed for the selected choice.
  5. Review the CMS website and Palmetto GBA site for teleconferences, webinars, and training material.
  6. Know the due dates for choice selection, prepare for implementation, evaluate staffing to meet the needs of record submission, and consider if additional or outsourced assistance is needed.

What has QIRT done to prepare? QIRT created:

  • The RCD Readiness Audit – Learn where your agency stands
  • The RCD Complete Guide to Success – The DIY agency option
  • QIRT Team of Experts – The outsourcing choice
The QIRT team learned a great deal from the PCR rollout in IL.

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