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Ohio is the winner of the lottery to determine which state gets to go second to try Medicare's replacement for its abruptly canceled Pre-Claim Review experiment. Known as "Review Choice Demonstration," Illinois Medicare home health providers — the only ones to test Pre-Claim before it was suspended following complaints about Palmetto's uneven, unpredictable application of its own rules — made their choices in April and May. Ohio HHAs must declare their choices during the four-week period beginning August 16 and ending September 15.

HHAs in participating states will theoretically have three payment system options, though no HHA will select choice number three, widely regarded as a thinly veiled, tongue-in-cheek threat by CMS.

  1. Pre-claim review, similar to the Illinois 2016 demonstration
  2. Postpayment review, similar to current MAC/ZPIC/UPIC/RAC procedures
  3. Little or no review, accompanied by a 25% reduction from the existing payment rate

A CMS bulletin advises Ohio HHAs to visit the Palmetto GBA provider portal for detailed explanations of their available choices and instructions on the selection process.

Palmetto GBA will also send letters to all Ohio HHAs detailing this information. HHAs that do not make a choice selection by September 15, 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 starting on or after this date will be subject to the requirements of the choice selected.

CMS will continue to post updated information on its website and we will monitor it as CMS adds the remaining demonstrates states of Texas, North Carolina, and Florida. CMS anticipates 60-90 days between beginning the demonstration in each additional state and Palmetto GBA will provide at least 60 days' notice in advance of the demonstration starting in each state.

CMS invites questions. Send them to:

RCD Background

  • On April 1, 2017, CMS paused the Pre-Claim Review Demonstration for Home Health Services to consider a number of changes in response to stakeholder feedback. (See Rowan Report 4/5/17: "Pre-Claim Review Shut Down - For Now")

  • On May 29, 2018, CMS first announced its intention to implement the Review Choice Demonstration for Home Health Services through a PRA notice and sought initial public comments.

  • On September 27, 2018, CMS published responses to initial comments and a subsequent PRA notice, and provided the public another opportunity to comment on CMS’ efforts to collect information on the revised demonstration. The second public comment period ended October 29, 2018.

  • Published responses and additional information on the demonstration design are available on the CMS Regulations & Guidance web page.


©2019 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.