CMS Picks Review Choice Demo Start Date, Releases New Details

The Centers for Medicare & Medicaid Services (CMS) has picked an official start date for its Review Choice Demonstration (RCD), an initiative meant to curb improper billing among home health providers.

On Wednesday, CMS announced RCD will begin in Illinois on June 1. For home health providers operating in Illinois, that means all episodes of care starting on or after that date will be subject to the requirements of the RCD option they ultimately choose.

The new start date is roughly six months later than the agency had originally planned.

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“Illinois is the first of five states participating in this demonstration that will ensure providers better serve their patients as timely and responsible stewards of the Medicare program,” CMS Administrator Seema Verma said in a statement shared with Home Health Care News. “We expect this demonstration to keep dollars in the Medicare program and away from unscrupulous providers.”

Ohio, Texas, North Carolina and Florida are set to follow Illinois under RCD, an updated version of CMS’s abandoned Pre-Claim Review Demonstration (PCRD) from a few years ago.

Unlike PCRD, which was relatively rigid, home health providers will be given multiple claims review options in RCD.

Those options include pre-claim review, post-payment review and a minimal post-payment review with a 25% payment reduction. Home health agencies that demonstrate compliance with Medicare rules will be given additional choices as well.

“CMS is committed to putting patients over paperwork and protecting taxpayer dollars,” Verman said. “To achieve this vision, we must ensure that strengthened enforcement preserves choice of services for beneficiaries and reduces burden on providers.”

The selection period

RCD doesn’t begin until June 1, but providers will need to select how they want to participate in the demo during a window that opens on April 17 and closes May 16.

Home health agencies that do not pick an RCD option by May 16 will be automatically placed in the post-payment review group.

Palmetto GBA — the Medicare administrative contractor (MAC) tasked with overseeing claims review under RCD —  plans to send out information letters to all Illinois home health agencies.

The revised pre-claim initiative should not delay care to Medicare beneficiaries and does not alter the Medicare home health benefit, according to CMS. Additionally, the agency says the demonstration will not create new clinical documentation requirements, with home health agencies expected to submit the same information they are currently required to maintain for payment.

CMS’s PCRD attempt was halted in early 2017 after home health providers reported widespread inconsistencies and delays throughout the pre-claim approval process.

While RCD alone presents a challenge to home health providers, it has the potential to become even more burdensome when paired with the Patient-Driven Groupings Model (PDGM), a major payment overhaul set to go into effect on Jan. 1, 2020.

In general, providers have been largely divided on the possible severity of RCD.

Improper payments

CMS’s renewed attempt to curb improper payments comes despite documented, industry-wide progress.

In fiscal year 2018, improper Medicare fee-for-service payments totaled $31.6 billion for all services provided, according to a recent report from the Government Accountability Office. Of that amount, at least $3.2 billion was tied to home health improper payments.

Overall, though, the home health improper payment rate has dropped substantially since 2015.

In 2018, roughly 18% of home health payments were categorized as improper. Just three years earlier, the improper payment rate hovered above 58%.

Improper payments most often arise as a result of documentation errors.

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