MACs Report Processing Glitches for No-Pay RAPs

Among payment-related policy changes for the home health industry in 2021 is the elimination of traditional Requests for Anticipated Payment (RAPs) — and the introduction of the “no-pay RAP.”

While the change is a potentially costly one for home health agencies, they’re not the only ones struggling to keep up. Medicare Administrative Contractors (MACs) have also reportedly experienced processing glitches in the first few weeks of the new year.

MAC Legacy — a Denton, Texas-based home health and hospice coding and consulting company — has reported that no-pay RAPs aren’t processing seamlessly. That, in turn, is causing them to be returned to providers.


The absence of a particular value code on the RAP claim is behind the issue, DeAnn Briscoe, senior director of clinical education at MAC Legacy, told Home Health Care News.

“In the new no-pay RAP rule of 2021, the U.S. Centers for Medicare & Medicaid Services (CMS) made it optional for agencies to include value code 61,” Briscoe said. “That code is a statistical area code, and it tells where the home health services were furnished.”

Specifically, the code designated if a patient was being served in a rural area.


While CMS never specified why code 61 became optional under the new rule, Briscoe believes this happened because there isn’t a payment assigned to no-pay RAPs, thus eliminating the need for a value code.

CMS confirmed its plan to eliminate RAPs in its 2020 rulemaking. Eventually, the no-pay RAP will be replaced with a one-time Notice of Admission (NOA) requirement, effective in 2022. An NOA establishes care in place of a RAP for a patient until they are discharged.

Currently, CMS requires home health providers to submit no-pay RAPs that will be paid at 0%, prior to each claim. During this transition period, no-pay RAPs serve as the bridge between RAPs and the upcoming NOA.

CMS is working on a solution to the processing issue. For now, it has adopted a temporary workaround.

“The workaround is when agencies submit their RAP to whatever MAC they’re under, those MACs have been educated, by CMS, to go ahead and add value code 61 if it’s not there,” Briscoe said. “They’re using a dummy CBSA code as a placeholder.”

When no-pay RAP processing issues first began to crop up in the second week of January, the National Association for Home Care & Hospice (NAHC) also began hearing from its members.

The organization was quickly able to determine that this was a CMS system glitch and not an individual contractor issue.

Since the dummy code workaround was established fairly quickly, it is unlikely that providers will be impacted long term, Mary Carr, vice president of regulatory affairs at NAHC, told HHCN.

In general, it’s difficult to determine exactly how well providers are adjusting to no-pay RAPs.

After some initial concern from providers about the five-day submission timetable, providers have been reasonably quiet on the matter. But the industry is still in the early days of the change, according to Carr.

“We haven’t heard a lot,” she said. “We heard a lot of anxiety back in December — very concerned about the five-day window. We’re not hearing anything now, but we’re not even at the 30-day mark yet.”

Moving forward, Briscoe stressed the importance of providers submitting no-pay RAPs on time.

“Agencies need to submit on time because the penalty for not doing so really adds up fast when you’re talking about a 30-day period of payment,” she said.

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