Home Health Experts Offer Update on Transition to No-Pay RAPs

It’s been 48 days since the start of “no-pay RAPs” in home health care. During this time, providers have had to navigate a sea of challenges and unexpected speed bumps while adjusting to the new process.

The U.S. Centers for Medicare & Medicaid Services (CMS) kicked off no-pay RAPs on Jan. 1 of this year. Broadly, the payment change is part of the agency’s plan to eliminate home health pre-payments and move toward a Notice of Admission (NOA) requirement next year.

In general, no-pay RAPs are a signal to notify Medicare that a beneficiary has begun to receive care from a certified home health provider.


A major question from providers has had to do with the processing time.

“So far it’s been similar to what it was before,” Nick Seabrook, managing principal and founding partner of BlackTree Healthcare Consulting, said during a recent webinar. “It’s taking three to five days for these RAPs to process and pay, even though we have a lot more limited number of data elements. And also there’s no payment being issued.”

One issue that has been uncovered during this time: Medicare Administrative Contractors (MACs) were experiencing processing glitches stemming from CMS’s decision to make the use of value Code 61 optional for providers.


Seabrook noted that while a temporary fix came quick — providers were asked to include value Code 61 when submitting RAPs — it was a time-consuming process for providers who submitted a high volume of claims.

Another issue that has cropped up has to do with RTP Reason Code W7216 and patients who had a 2020 start date and a 2021 end date. These are known as “cross-over patients.”

“One of the things we are suggesting as you’re going through and fixing these RAPs … is if you do have a claim in RTP and it’s outside that five-day window, you want to make sure you’re taking a screenshot, just so you have proof of what the received date was,” Seabrook said.

Some final claims issues have also popped up. During a period from Jan. 4 to Jan. 8, MACs did not receive OASIS file responses.

“It’s since been resolved,” Seabrook said. “For this instance, there is an RTP reason where it’s not seeing a matching OASIS to go with the claim information that they need in order to actually price it.”

Another issue relates to LUPA claims. Some of these claims are being incorrectly rejected and labeled as untimely.

For the most part, there has been a typical response pattern when it comes to no-pay RAP issues.

“You’ll start seeing these issues come up, then at some point in time, you’ll see Medicare or one of the MACs acknowledge it,” David Hoover, vice president of revenue cycle management at Axxess, said during the webinar. “It’s not going to be a formal acknowledgment, but they’ll acknowledge that there’s a problem. It’ll take a few days, … and they’ll come up with the fixes. So it’s something that kind of evolves.”

There are a few key operational steps providers can take at this time in order to stay on top of everything. This includes entering valid primary diagnoses code from referrals at intake, increasing billing frequency of RAPs to daily and reviewing RTP files daily.

“Making sure that you’re reviewing that RTP file daily, and making sure that you’re getting those in is a big operational practice that can help you save some time and effort in the long run,” Hoover said.

Any kind of delay or processing issue when it comes to RAPs is significant due to potential penalties. No-pay RAPs have to be submitted within five calendar days after the start of each 30-day period of care. Providers face a 3% fine for each day they’re late.

In the past, roughly 22% of providers took 15 days or more to file RAPs, according to BlackTree data.

Industry insiders will know more about the overall impact of the no-pay RAP in the weeks to come.

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