Medicare Compliance & Reimbursement

REIMBURSEMENT:

CMS Steps In to Mitigate Effect Of RAP Delay

Error can't be fixed this late in the game, feds say.

Home health agencies (HHAs) in 16 states are wrestling with Palmetto GBA over what's being called an "improper" hold on request for anticipated payment (RAP) disbursements from Sept. 22 through Sept. 30.

The National Association for Home Care (NAHC) reported on Aug. 21 that the Centers for Medicare & Medicaid Services (CMS) has indicated they will "step in to see that home health agencies [in the region] are not harmed" by Palmetto's proposed hold.

Background: Although the Deficit Reduction Act of 2005 does mandate a payment hold on Medicare Part A and B claims between Sept. 22 and Sept. 30, a home health RAP is not a "claim" as defined by law, explains NAHC.

Earlier this year, CMS agreed with NAHC that RAPs would not be subject to the hold, the trade group reports. Palmetto, however, announced this month that the delay will affect RAPs.

Though CMS has confirmed that the RAP hold is in error, the agency says that it's too late to fix the problem, which involves the HIGLAS (Healthcare Integrated General Ledger Accounting System) claims accounting system used by Palmetto.

CMS has adopted a suggestion from NAHC that agencies in Palmetto's jurisdiction should receive an advance of estimated RAP payments to cover the payment delay, reports NAHC.

Though the trade group and CMS are still working on details of the planned remedy, NAHC recommends that Palmetto do one of the following:

1. Implement an efficient accelerated payment method that does not require HHAs to submit the high level of paperwork normally required; or

2. Establish an interim payment methodology that permits HHAs to receive an estimated payment for nine days of RAPs, based on their recent history of RAP payments.
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