RCD Hits Pause – Don’t Mess With Texas?

Texans have a saying that embodies their independence and pride in their state: “Don’t Mess With Texas!” Now it seems that after first announcing that Review Choice Demonstration (RCD) was going to start in Texas on December 2, 2019, CMS has changed its mind. As CMS hits pause on RCD, this should remove, or at least delay, part of the double-dose of home health stress that Texas faced in the coming months. The second stressor is the January 1, 2020 implementation of the Patient-Driven Groupings Model. Taken together, intense changes were heading straight for Texas agencies.

Look here for further details on the current CMS plans.

Why the Delay?

In an October 21, 2019 update CMS states:

“To allow Home Health agencies to transition to the Patient-Driven Groupings Model (PDGM), which becomes effective on January 1, 2020, CMS is rescheduling the implementation of the Home Health Review Choice Demonstration (RCD) for the remaining states of Texas, North Carolina, and Florida. The demonstration is expected to begin in Texas on March 2, 2020. The choice selection period will begin on January 15, 2020, and end on February 13, 2020, for Home Health Agencies (HHAs) located in Texas, who submit claims to Palmetto GBA, the Jurisdiction M Medicare Administrative Contractor (MAC).”

cms.gov

This change also affects the selection period for Texas agencies that had prior began on October 16, 2019. Palmetto GBA has posted this information here.

Any Other Pause on RCD That I Should Know About?

Not a pause so much as a delay. CMS has also pushed back the RCD implementation date for North Carolina and Florida from March 30, 2020, to the new date of May 4, 2020. There is also one more key item related to RCD. When PDGM is implemented, the prior exclusion of Low Utilization Payment Adjustment (LUPA) claims is changed: all claims will be subject to the selected RCD Choice. This will also apply to Illinois and Ohio home health agencies who are currently undergoing RCD. So Texas home health agencies get an opportunity to adjust to the realities of PDGM before submitting their claims to RCD scrutiny. This should offer agencies there a better chance of weathering the burden of these two issues.

More on RCD

After a pause of more than a year, CMS began orchestration of the pre-claim review (PCR) demonstration project in five selected states. Review Choice Demonstration (RCD) for Home Health Services is the new name for pre-claim reviews and there are some changes. First of all, tweaks in the new process “offer more flexibility and choice for providers, as well as risk-based changes to reward providers who show compliance with Medicare home health policies.”

In addition to the 100% pre-claim review option of PCR, home care agencies will now be able to choose a 100% post-payment option. Essentially this new option in RCD means putting themselves on a 100% Additional Development Request (ADR) review. As before, agencies can also opt to not send any claims for pre-claim or post-payment review. The result? They suffer an automatic 25% payment reduction. Read more of QIRT’s initial assessment of the RCD rollout in this blog post from 10/18/18.

QIRT can help.

If you are feeling overwhelmed, reach out for assistance in assessing your current status before RCD goes live in your state. QIRT experts will assess your agency’s needs.

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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