‘Don’t Panic’: NOA Launch Leaves Home Health Providers Navigating a Sea of Issues

For home health providers, the transition to the no-pay Request for Anticipated Payment (RAP) was a period of adjustment. Now, the Notice of Admission (NOA) has replaced the RAP, and providers are grappling with a number of issues that have cropped up amid the launch of the new process.

Last year, the U.S. Centers for Medicare & Medicaid Services (CMS) kicked off no-pay RAPs as part of its plan to eliminate home health pre-payments and as a prelude to the NOA requirement that began on Jan. 1.

Broadly, an NOA is a one-time submission that alerts CMS when a patient has been admitted to home health. An NOA also covers contiguous 30-day plans of care until the patient is discharged.

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“This helps with consolidated billing; it is faster than waiting until the claim is processed,” Katie Wehri, director of home health and hospice regulatory affairs at the National Association for Home Care & Hospice (NAHC), told Home Health Care News. “When RAPs were eliminated, there had to be something that would take its place to identify when a patient was admitted. The NOA is that, and it’s a little less complicated than the RAP.” 

While the NOA was meant to be less complicated, its launch hasn’t lived up to that goal.

“It’s been kind of painful, and we sort of anticipated this possibility because of what we experienced last year with the no-pay RAPs,” Aaron Little, managing director at BKD, told HHCN. “This change, as it’s laid out on paper, doesn’t seem terribly difficult. But when you think about unraveling the last 20 years of claim edits, and what EMR vendors have to go through to rewire their systems, it really is a big change.” 

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BKD is a Springfield, Missouri-based accounting services firm that provides billing and revenue cycle outsourcing services.

From the start, providers reported that when they submitted an NOA it would not always show up in the system, according to Wehri.

All three of the Medicare Administrative Contractors (MACs) were experiencing issues when it came to processing NOAs correctly.

“It turns out there was a CMS claim-processing issue or a system issue,” Wehri said. “A zip code is required and, for some reason, the zip code was being stripped. Since this was a CMS problem, all of the MACs had to address that. They implemented the fix that is part of the CMS system to allow that code to process properly and not to be stripped from the NOA.”

Wehri noted that this fix was implemented last week. As for NOAs processed before this fix, the MACs have introduced workarounds. This information should be available on the MACs claims processing issues log or production alert.

However, one MAC – Palmetto – was still experiencing issues as of last week. Every quarter a system update takes place. When this happens, a MAC can hold claims temporarily for about two weeks. The hold is to ensure that everything in the system that has just been updated is processing properly.

“It turns out there were some NOAs that were held as part of that quarterly release,” Wehri said. “That happened on the Palmetto side. For some reason, some of those NOAs had condition code 47 removed and replaced with condition code 15, which caused them to return to the provider.”

Last week, Palmetto posted a message letting providers know they are working on correcting these issues. For now, providers who have already submitted NOAs are advised to sit tight.

“We have talked with Palmetto, and we understand that it’s better if providers don’t take any action,” Wehri said. “If there is an NOA that was part of this issue with Palmetto, it will be identified by code 19960. Palmetto is going into the system, locating those NOA IDs and correcting them.”

Challenges have also popped up on the EMR side, according to Little.

“They’re kind of wide-ranging,” he said. “Some of the EMRs are still having trouble producing the electronic file. For some, it’s not so much that they’re not producing the file, it’s that the triggering and reporting mechanism isn’t necessarily giving the alerts the way they should.”

Right now, it’s important for providers to be diligent and identify the capabilities and limitations of their EMR.

“If you know that your EMR is not going to be able to give you consistent alerts about certain types of patients for certain scenarios, … then you’re going to need some kind of workaround,” Little said. “Be diligent and stay on top of your MAC. This means communicating.” 

Though the transition to NOA hasn’t been particularly smooth, Little believes that providers shouldn’t panic.

“Don’t panic, even though it’s a little frustrating,” he said. “Don’t avoid submitting an NOA just because you don’t think it’s going to process. You’ve got to be able to show that you made an attempt even if there’s a processing issue.”

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