‘This Is the Biggest Break We’ve Had’: CMS Makes Major Alteration to Review Choice Demonstration

The U.S. Centers for Medicare & Medicaid Services (CMS) has made a major update to the Review Choice Demonstration (RCD), one that home health providers will undoubtedly be thrilled about.

On Sept. 1, agencies in Florida and North Carolina are set to roll out RCD. One of the major complaints as the date loomed was a stipulation that would subject claims made prior to Sept. 1 to RCD, retroactively.

So if the dates of service were in, say, May of this year — but the billing wasn’t processed until September — the provider would be subject to the post-Sept. 1 rules of RCD.

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That has been changed.

“After further discussions, we are modifying our Florida and North Carolina implementation plans such that only those claims with dates of service beginning on and after Sept. 1, 2021, will be subject to ADR/prepayment review if they are submitted without a UTN/pre-claim review decision,” CMS told provider groups Thursday. “We hope that this alleviates some of the concerns you mentioned and will help providers focus on new and upcoming dates of service as they transition to the demonstration processes.”

Put simply, the adjustment is a gift to providers, especially considering how rampant COVID-19 is currently in North Carolina, and more particularly, in Florida.

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“We have dodged some RCD bullets over and over again,” Bobby Lolley, the executive director of the Home Care Association of Florida (HCAF), told Home Health Care News. “But this, I feel, is the biggest break that we’ve had because of how tough things are in Florida. Providers are telling me this is the worst it’s been from a COVID perspective since the beginning of the pandemic.”

Between RCD rollout and COVID-19 pressure, providers and associations alike were particularly concerned about the now-changed stipulation.

“Agencies are struggling and have a whole lot of claims backlog that they would have to then push through RCD,” Lolley said. “So this change is just huge. … And I’m one thankful guy.”

RCD will still begin Sept. 1 as anticipated, and plenty of providers in the two states have already geared up for it for the better part of the year. While others haven’t and still have a lot of change ahead, they’ll at least have one less concern.

Lolley specifically thanked the National Association of Home Care & Hospice (NAHC) for its help with the advocacy efforts.

“I give a huge amount of credit to NAHC, [which] has made real good relations with a new administration and new people at CMS,” Lolley said. “When they reached out to see how big of an issue this was, we told them some providers said it could put them out of business. … So they did an excellent job, and it worked.”

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