The Review Choice Demonstration (RCD) is expanding.
The Centers for Medicare & Medicaid Services (CMS) announced Monday that home health providers in Ohio will be next in line for RCD, a revived version of the failed Pre-Claim Review Demonstration (PCRD) meant to combat improper billing. Home health providers in Illinois — the only state with pre-claim experience — have been participating in RCD since June 1.
PCRD was paused in 2017 just one day before it was set to begin in Florida, largely due to widespread administrative issues and review problems. Ultimately, regulators had planned for a pre-claim rollout in Texas, Massachusetts and Michigan as well.
Michael Vallee, CEO of Your Choice Health Care Group, told Home Health Care News that it is “disappointing” Ohio was picked as RCD’s next target, given the fact that PCRD wasn’t even on providers’ radars a few years ago. Your Choice Health Care Group operates four standalone, full-service home health agencies that serve a dozen Ohio counties.
“I’m sort of upset Ohio was chosen,” Vallee said. “We weren’t in the first go-around at all.”
Broadly, RCD requires home health providers to show compliance with Medicare rules through either pre-claim or post-review processes. Agencies can also opt for minimal post-payment review, though that means agreeing to a 25% payment reduction.
Additional choices exist if providers demonstrate a proven track record of Medicare compliance. As part of RCD, CMS is working with Medicare Administrative Contractor (MAC) Palmetto GBA.
Ohio home health providers will be able to pick how they operate within RCD from Aug. 16 to Sept. 15.
The official start date in Ohio is Sept. 30.
“The reality is this: Pre-claim didn’t work the first time around when it was in Illinois, and I do not believe [regulators] have given it enough time to make sure it’s working this second time around there,” Vallee said. “The last phone call that we took part in with Palmetto, there was a number of extremely agitated Illinois home health agencies that had things to say about [RCD] — and very few of them were positive.”
CMS anticipates 60 to 90 days between beginning RCD in the remaining target states of Texas, North Carolina and Florida. CMS and Palmetto GBA will provide at least 60 days of notice in advance of the demonstration starting, according to the agency.
In addition to the challenges that come with RCD itself, some home health providers have expressed concern with navigating the demo while simultaneously juggling everything that comes with the Patient-Driven Groupings Model (PDGM).
Vallee said he shares those worries.
“We heard rumors that Medicare [policymakers] were actually concerned about that, too — RCD, PDGM and how the two of those are going to work together,” he said. “Obviously, they made a decision that they can [work together].”
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