CMS Pauses RCD in Two States Ahead of PDGM — But Moves Ahead in Texas

Good news for home health providers in North Carolina and Florida: The Centers for Medicare & Medicaid Services (CMS) will delay the implementation of Review Choice Demonstration (RCD) so agencies can adapt to the upcoming Patient-Driven Groupings Model (PDGM) first.

Providers in Texas, however, won’t be as lucky.

CMS announced Wednesday it is moving forward with RCD in Texas ahead of PDGM. The demonstration will begin Dec. 2, just 30 days before the revolutionary new reimbursement methodology takes effect nationwide.

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Meanwhile, RCD will pause after that “to allow for the transition to … PDGM” in North Carolina and Florida, according to CMS. The demo is expected to begin in those states March 30, 2020.

The news came as a disappointment to national and Texas state associations representing home health providers, which continue to advocate for the delay of RCD in Texas. Specifically, they worry the combined burdens associated PDGM and RCD may be too much for providers — especially smaller ones — to handle.

“The combination of PDGM and RCD so close together … will have a devastating impact on agency cash flow and operations, forcing many agencies out of business and creating needless access-to-care issues for Medicare beneficiaries who need this critical care at home,” Rachel Hammon, executive director of the Texas Association for Home Care & Hospice (TAHCH), told Home Health Care News.

National Association for Home Care & Hospice (NAHC) President William A. Dombi echoed those concerns. Like TAHCH, NAHC is working to communicate potential problems of the dual rollout to CMS.

“The payment reforms are the most significant operational changes for home health agencies in the last 20 years,” Dombi told HHCN. “The work need[ed] with PDGM is ongoing and will be at its highest intensity in November and December. Texas home health agencies need to be focused on PDGM, not RCD paperwork.”

RCD, which has already begun in Illinois and Ohio, is designed to cut down on improper billing and allows the government to review home health agency claims for accuracy. It was born out of the failed Pre-Claim Review Demonstration (PCRD), which was paused in 2017 after causing administrative and review problems in Illinois, the only state to implement the demonstration.

Florida legislators were instrumental in the original stoppage of PCRD.

“I’m encouraged by CMS’s decision to delay the Home Health Pre-Claim Review Demonstration from taking effect,” Sen. Marco Rubio (R-Fla.) said in a statement to HHCN in March 2017. “It’s my hope this process ultimately results in a better program that more effectively targets fraud.”

Unlike PCRD, RCD gives providers choice in how the government reviews their claims. Agencies can choose a pre-claim review option, a post-payment review option or a minimal review option, which comes with an automatic 25% payment reduction.

From there, compliance can open pre-claim and post-payment providers up to even more options going forward. Every six months, agencies will receive their claims approval rate. If that rate is 90% or higher, providers can also choose selective post-payment review and spot-check review options.

So far, pre-claim review has proven to be the most popular option among home health providers in Illinois and Ohio.

Currently, Texas agencies will have the opportunity to choose their review choice between Oct. 16 and Nov. 14, with agencies who don’t choose being automatically funneled into the post-payment review camp.

Still, TAHCH and NAHC are holding out hope for a delay.

“CMS should delay any further rollout of RCD until March for the three remaining states and gather data from Ohio before rolling out RCD to Texas, Florida and North Carolina in the wake of PDGM,” Hammon said. “We are working closely with our national partners and our Texas delegation to deliver this message to CMS loud and clear.”

Illinois has been participating in RCD since June 1, while the demonstration kicked off in Ohio on Sept. 30.

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