Home Health Advocates Strike Key Victory, Win RCD Delay

Home health advocates have struck an important victory in the battle against the Review Choice Demonstration (RCD).

The Centers for Medicare & Medicaid Services (CMS) announced Monday that the agency will delay RCD until March 2. The demonstration had previously been targeted for a Dec. 2 start date, meaning Texas home health providers would have had to simultaneously deal with RCD while transitioning into the Patient-Driven Groupings Model (PDGM).

“Honestly, this is the best news CMS has put out all year for us,” Summer Napier, CEO of Wichita Falls, Texas-based Healing Hands Healthcare, told Home Health Care News. “You know it’s exciting when [the National Association for Home Care & Hospice] sends the email out and the entire office starts jumping up and down, screaming with excitement.”

Healing Hands Healthcare is a for-profit, locally owned and operated in-home care provider that serves 22 counties in north-central Texas. Its offerings range from skilled nursing care and therapy services to medical license social working and private-duty services.

A revived version of the Pre-Claim Review Demonstration (PCRD), RCD has already started in Illinois and Ohio.

Broadly, the demo is meant to curb improper billing by requiring home health providers to submit Medicare claims for a comprehensive review by a Medicare Administrative Contractor (MAC). The Medicare fee-for-service improper payment rate was 8.12% in 2018, down from 9.51% in 2017.

There are multiple options for that comprehensive review under RCD, including both pre-claim and post-payment options. Providers can also opt into a minimal review choice, though doing so causes them to get hit with a 25% payment reduction.

Other options exist for home health providers that show a history of billing compliance.

Once RCD does eventually begin in Texas, Healing Hands Healthcare plans to follow the pre-claim route, according to Napier.

“We are going to go with pre-claim review,” she said. “It was a no-brainer for us. We have nothing to hide, and we are confident in our intake process.”

With the delay until March 2, the choice selection period for Texas home health providers will now begin on Jan. 15, ending on Feb. 13. Following the start of RCD in Texas, the demonstration is expected to begin in North Carolina and Florida on May 4.

“CMS will monitor the transition to PDGM and assess the need for any change to this date,” agency officials wrote in the delay announcement.

Apart from the delay itself, CMS also stated that, with respect to PDGM, it will phase in the inclusion of Low Utilization Payment Adjustments (LUPAs) within the Review Choice Demonstration (RCD).

Currently, home health providers are hit with a LUPA if they provide four or fewer visits during a 60-day episode of care to any category of patient. PDGM takes that single standard and introduces hundreds of different LUPA scenarios.

Delaying RCD will be particularly helpful for smaller home health agencies that don’t have vast resources to swiftly take on added regulatory burdens, according to Napier.

“While this affects all agencies, for smaller agencies that don’t have central intake and central billing offices, the administrative burden it places on organizations to either hire someone new for data collection or reassign an employee to learn this role is a big one,” she said. “By giving Texas a chance to get acclimated to PDGM, I think it will be a natural flow of business to learn how to incorporate RCD into that.”

The timing of PDGM and RCD was a common point of conversation at NAHC’s annual leadership conference in Seattle last week.

Originally, CMS had somewhat underestimated the burden associated with planning for PDGM in December, according to NAHC President William A. Dombi.

“They didn’t understand. They said, ‘[PDGM] doesn’t start until January, so you don’t have a workload with that until January,’” Dombi said in Seattle. “We conveyed to them fairly persuasively that PDGM probably brings a greater workload in November and December than it will bring in January.”

NAHC had been expecting feedback from CMS on the Texas RCD-PDGM timing since last Friday.

Despite the delay in Texas and clear victory in the present, providers shouldn’t expect CMS to drop RCD completely in the future.

“I do not see any chance that they’re going to ack away from doing this on a permanent kind of basis,” Dombi said.