RCD Marches On

After restarting the Review Choice Demonstration (RCD) project in Illinois on June 1, CMS announced yesterday that Ohio is next up and will start RCD on September 30, 2019.  The order and specific timing of the remaining states to start RCD (Texas, Florida, North Carolina) is still not provided. However, we do know that each upcoming state will receive at least 60 days’ notice before starting RCD in each of those states. Our experts have been working with Illinois agencies. Check out previous blog posts for more information and in-depth analysis.

Three Choices:

As a revamped version of the prior Pre-Claim Review Demonstration, RCD offers three choices to home health agencies to have their records scrutinized for proper payment and compliance with Medicare eligibility and coverage requirements. 

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

Palmetto GBA has indicated that they will send letters to Ohio agencies informing them of their options, but 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. Palmetto has stressed that agencies can only make their selection via eServices. 

Let’s Recap:

The RCD choice selection period for home health agencies located in Ohio will begin on August 16, 2019 and end on 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. Additionally, Palmetto GBA will send letters to all Ohio home health agencies detailing this information. Ohio home health agencies that do not make a choice selection by September 17, 2019 will be automatically placed in Choice 2: Postpayment 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 – starting on or after this date will be subject to the requirements of the choice selected. 

Take Action 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 the referral, face-to-face encounter documentation, plan of care generation, OASIS assessment completion, and 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 RCD 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. 

More RCD Info

QIRT is here to help with two support options.

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!

QIRT Expert Help

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