The Request for Anticipated Payment (RAP) has been in place since the implementation of the Home Health Prospective Payment System (PPS) on October 1, 2000.
The RAP has evolved over the years, but 2021 marks its ﬁnal year in existence. As Medicare home health billers will know, the RAP is required to be ﬁled within ﬁve days of the beginning date of the payment period. A monetary penalty is calculated from the date the period is to begin until the day before the accepted day if the RAP is not accepted in the ﬁve-day window. The 2021 RAP currently has no payment implications; it is simply a placeholder for establishing the payment period.
Moving into 2021, the RAP became what is referred to as a “No-Pay RAP” and carried the penalty as previously described. There was much confusion surrounding why the transition to the Notice of Admission (NOA) didn’t happen in 2021 instead of the madness surrounding the No-Pay RAP this past year. The only response was that the Centers for Medicare & Medicaid Services (CMS) Medicare Administrative Contractors (MACs) could not have the system ready to handle the NOA in 2021.
In May 2021, CMS released a memo oﬃcially stating that the RAP will be replaced with a NOA eﬀective January 1, 2022. This notice was updated in June 2021 and, additionally, Medicare Learning Network (MLN) Matters article MM12424 was issued in September 2021 following the release of Change Request 12424 to provide additional manual instructions for the coming NOA.
2022 NOA AND 2021 NO-PAY RAP: WHAT IS THE SAME?
The content of the NOA and the No-Pay RAP is very similar. Home health agencies (HHAs) will still have ﬁve days to submit a NOA and ensure it is accepted in the MAC’s claims processing system. It is necessary to be aware that the NOA and current No-Pay RAP must be accepted by the MAC in the ﬁve-day window. The language in the regulation states it must be submitted in ﬁve days, but the MAC has no idea when it was submitted. All they know and can prove is the date that it is accepted.
The requirements that must be met before submission are the same as for the No-Pay RAP:
- The HHA has obtained a verbal or written order from the physician that contains the services required for the initial visit, and
- The HHA has conducted an initial visit at the Start of Care (SOC).
Most elements required on the RAP are also required on the NOA.
2022 NOA AND 2021 NO-PAY RAP: WHAT IS DIFFERENT?
- The requirement for a valid Health Insurance Prospective Payment System (HIPPS) code remains if you are submitting the NOA via an 837I electronic claims ﬁle. Most will be submitted this way, so the default HIPPS code of “1AA11” should be used.
- The service date will only be required on the NOA if it is being ﬁled in an 837I electronic claims ﬁle. When using the 837I format, use the admission date as the service date.
- Value codes are not required on the NOA.
- The patient discharge status code used on the RAP (30) will only be required on the NOA if it is being ﬁled in an 837I electronic claims ﬁle. When using the 837I format, use the default status code of “30”.
- The NOA will only be required once for any series of home health billing This is typically at the SOC. Please see the following page for the exception with subsequent 30-day periods that begins in 2022.
- Penalties for the current No-Pay RAP being late are limited to 30 The NOA penalties will be from the beginning until the NOA is accepted by the MAC. If the NOA is three months late and the patient is still on service, the penalty will be three months.
RETIRING OF THE NO-PAY RAP
All 30-day payment periods that begin on or before December 31, 2021, will require a No-Pay RAP to be sent. This means that there will still be RAPs to be followed up on and penalties that could continue to aﬀect payment from late RAPs in 2022. The key is remembering that the No-Pay RAP retirement date is based on dates of service.
SUCCESSION OF THE NOA
The NOA will be escorted in, also based on dates of service. Any 30-day billing period that begins on January 1, 2022, and later will require that a NOA be ﬁled within ﬁve days of the beginning date of that 30-day period. One major caveat is that technically the NOA is only required at a new SOC and only at the SOC. There will not be NOAs for every 30-day payment period. However, if a patient has a start date that begins on December 31, 2021, or prior and a subsequent 30-day period begins January 1, 2022, or later, the instructions include that the HHA should submit a NOA with a one-time, artiﬁcial “admission” date corresponding to the “From” date of the ﬁrst 30-payment period beginning in 2022.
EXCEPTIONS FOR LATE NOA AND NO-PAY RAP
If an HHA fails to ﬁle a timely NOA or current No-Pay RAP, it may request an exception that, if approved, waives the consequences of it being late. The four circumstances that may qualify the HHA for an exception are as follows:
- Fires, ﬂoods, earthquakes, or other unusual events that inﬂict extensive damage to the HHA’s ability to operate.
- An event that produces a data-ﬁling problem due to a CMS or A/B MAC (Home Health and Hospice, or HHH) systems issue that is beyond the control of the HHA (this will rarely if ever be a successful exception if one agency had an issue that no one else experienced).
- A newly Medicare-certiﬁed HHA that is notiﬁed of that certiﬁcation after the Medicare certiﬁcation date, or which is awaiting its user ID from its A/B MAC (HHH).
- Other circumstances determined by the A/B MAC (HHH) or CMS to be beyond the control of the HHA.
CMS will not grant exceptions in the following situations:
- When the HHA could have corrected the NOA without waiting for Medicare systems actions.
- When the HHA has submitted a partial NOA to fulﬁll the timely ﬁling requirement.
- When the HHA has multiple provider identiﬁers and submits the identiﬁer of a location that didn’t provide the service.
The RAP has been a part of home health for more than two decades. It may be hard for some to see it be retired, but there will be others who are going to celebrate. The NOA will boldly make its presence known in 2022 and hopefully bring some relief from the anxiety of the RAP requirements every 30 days.
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Originally Published in HCAF HomeCare Magazine Winter 2021