by Darcey Trescone
Starting January 1, 2022, Medicare began requiring Home Health Agencies to submit a one-time Notice of Admission (NOA) instead of Requests for Anticipated Payment (RAPs). HHAs should no longer submit RAPs for any home health periods of care with a "From" date on or after January 1, 2022.
The industry has been aware of the upcoming NOA process change for some time. Over the past year, there have been multiple educational webinars, content pieces, and notices put out by CMS and the MACs regarding the NOA process and nuances. A "Home Health Notice of Admission Frequently Asked Questions" became available on 12.20.21 to further assist with the change.
HHAs should be outlining and testing their internal processes for NOA submissions to ensure they align with the regulations defined by CMS and the MACs. In addition, with only a 5-day window for NOA submission, HHAs should be working closely with their software vendors to ensure the NOA process needs are supported within their existing EMR.
We caught up with Aaron Little, Managing Director BKD, and Elizabeth Wilson, Senior Managing Consultant with BKD, this week to discuss challenges with the NOA process that they have identified.
Little: "We see issues with the NOAs, but so far, the issues that we see are specific to the EMR vendors. It is too early to know what kind of CMS issues there might be. We have submitted NOA EDI transaction files to the MACs but haven't yet seen the NOAs become visible in DDE, which we are hoping is resolved in the next day or two."
Additional challenges with the NOA will likely arise with scenarios such as transfers to and from other healthcare facilities and home health agencies. (An area addressed in the FAQs on the Palmetto website).
Released on August 31, 2021, the detailed job aid discusses codes and content required on claims, but it also reiterates important considerations regarding NOAs:
Since it is still early days, HHAs should anticipate confusion around information submitted on the NOA, billing claims, and potential challenges with the MACs and CMS. Monitoring for timely submission of accurate NOAs is essential, but it is equally essential to understand how the EMR in use will support the requirement. HHAs need to work closely with their software vendors, perhaps also tapping the skills of other industry experts, to ensure accurate, timely NOA submission to avoid unnecessary payment penalties.
Also see: CGS: Tips on HH NOA, released January 4, 2022.
Darcey Trescone is a Healthcare IS and Business Development Consultant in the Post-Acute Healthcare Market with a strong background working with both providers and vendors specific to Home Care and Hospice. She has worked as a home health nurse and held senior operational, product management and business development positions with various post-acute software firms, where her responsibilities included new and existing market penetration, customer retention and oversight of teams across the U.S., Canada and Australia. She can be reached at email@example.com.
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