Home Health Agencies Plan Ahead for Full-Blown RCD Resumption

Earlier this month, the U.S. Centers for Medicare & Medicaid Services (CMS) announced it will not immediately pursue a full-blown restart of the Review Choice Demonstration (RCD), a regulatory initiative designed to reduce improper billing in home health care.

Instead, CMS outlined how it will move forward with a “phased-in approach” to RCD that gives home health providers more flexibility in how and when they participate. RCD — a revised form of the failed Pre-Claim Review Demonstration (PCRD) — includes providers in Illinois, Ohio, Texas, Florida and North Carolina.

New survey data collected by the Home Care Association of Florida (HCAF) now reveals how providers plan to proceed.


Under CMS’s new phased-in approach to RCD, home health providers in Florida and North Carolina have three general options.

They can gradually increase claims to achieve 100% compliance within 60 days, submit some claims just to test the system out or submit no claims until doing so becomes mandatory.

“Between learning how to navigate under the Patient-Driven Groupings Model (PDGM), the Electronic Visit Verification (EVV) mandate, Accountable Care Organizations (ACOs) and the Value-Based Purchasing Demonstration — not to mention the public health emergency — Florida providers are stretched thin and simply just need time to put out one fire before they can take on another,” Patti Heid, HCAF’s director of regulatory affairs and compliance, told Home Health Care News.


In the HCAF survey of nearly 130 home health professionals, 72% of respondents said they planned to gradually increase claims to achieve 100% compliance within 60 days. About 23% said they planned to submit some claims just to become more familiar with RCD before fully diving in.

Less than 5% of respondents in HCAF’s survey said they will not submit any claims until RCD participation becomes mandatory.

Broadly, the survey results underscore how home health providers are willing to comply with the somewhat controversial RCD moving forward, HCAF Executive Director Bobby Lolley told HHCN.

“These numbers show what many of us believed to be true — that Florida providers were not just trying to dodge RCD but are actually willing to face it and tackle it even when there is little data that supports the need for such a demonstration project,” Lolley said. “Our [home health] community here in Florida just needed additional time because of all of the challenges and difficulties that the COVID-19 pandemic is still bringing to their door every day.”

The 2019 fee-for-service Medicare improper payment rate was 7.25% — or $28.91 billion in improper payments. Meanwhile, the 2018 estimated improper payment rate was 8.12%, which represented $31.62 billion in improper payments.

A substantial dip in home health improper payments was one of the key reasons for that annual decrease.

In other words, home health providers were making progress on their ability to file accurate, error-free claims before RCD went into action.

HCAF shared its survey findings during a Thursday webinar. Healthcare Provider Solutions Inc. CEO Melinda Gaboury was among the speakers.

“I feel that the high percentage of participants that intend to participate and gradually increase to 100% submission in 60 days shows that agencies are ready to begin the process and have been preparing with the awesome leadership and education from HCAF,” Gaboury told HHCN. “There is a difference in being a victim and overcoming [a challenge] versus being a victim and letting it defeat you. Florida providers are often the victim of scrutiny, but they have and will continue to prevail.”

Home health providers in North Carolina are chosing similar paths, according to Tim Rogers, president and CEO of the Association for Home & Hospice Care of North Carolina.

Data collected by the Association for Home & Hospice Care of North Carolina shows that nearly 41% of providers are chosing the “gradually increase claims” option, with nearly 48% choosing the “test” option.

Less than 12% of North Carolina providers are choosing not to submit any claims until it is mandatory to do so.

Home health providers in Illinois, Ohio and Texas do not have the same flexibilities.

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