Review Choice Demonstration Clears Hurdle, Likely Starting Soon

The Review Choice Demonstration (RCD) is likely right around the corner for Illinois home health providers.

The Centers for Medicare & Medicaid Services (CMS) announced March 4 it had received Paperwork Reduction Act approval for RCD from the White House Office of Management and Budget (OMB). Since OMB approval, the agency has been finalizing the choice selection process for home health agencies, a CMS spokesperson told Home Health Care News in a Wednesday email.

CMS was still unable to provide an exact start date, however.

RCD was originally targeted for an Illinois launch date of Dec. 18, 2018.

The demonstration — applicable only to home health agencies in the states that currently submit claims to Medicare administrative contractor Palmetto GBA — will begin in Illinois before being phased into Ohio, Florida, North Carolina and Texas.

CMS and Palmetto GBA will provide at least 60 days’ notice before RCD starts in each of the additional four states outside of Illinois, according to the spokesperson.

That collection of states was specifically chosen, the spokesperson said, because they have a history of “extensive” Medicare home health fraud. Illinois was chosen as the first state under the demo due to its comparatively smaller claim volume — and because Illinois home health providers already went through the Pre-Claim Review Demonstration (PCRD) back in 2016.

PCRD — designed to combat improper billing — was ultimately paused after home health providers experienced widespread delays and paperwork challenges.

“You guys are probably prepared for it if you continued the practices you did during pre-claim review. If is a big if,” National Association for Home Care & Hospice President William A. Dombi recently said while speaking at an Illinois HomeCare & Hospice Council (IHHC) event. “If you fell back on some of the old practices in terms of documentation, you will be haunted by this business model.”

While PCRD was relatively rigid in structure, RCD is meant to offer more flexibility.

Home health agencies operating in active RCD states for the first time will have three immediate options for claims review and approval: a 100% pre-claim review, a 100% post-payment review and a minimal review option that includes a 25% payment reduction.

Agencies that choose the pre-claim review or post-payment review option and maintain high compliance levels will be eligible for additional options, including, for example, a selective post-payment review and a spot-check review of 5% of claims on a biannual basis.

“More details will be coming soon,” Liz Vogt, director of regulatory and government affairs at IHHC, said during the event. “So, assuming there are no major changes to the proposal, you certainly need to make sure you’re logged in, your password works, and you have access to Palmetto GBA’s e-portal.”

Home health providers will have as little as two weeks from the time CMS announces an official start date to the ultimate deadline to make their RCD choice selection, Vogt said.

“Any time from two weeks to 30 days,” she said. “That timeline has not been finalized yet.”

The Office of Inspector General and the U.S. Department of Justice also helped CMS identify RCD states.

Additional reporting by Bailey Bryant