CMS Seems Intent On Sticking With Home Health Care’s Review Choice Demonstration

The Review Choice Demonstration (RCD) has received a set of diverse reactions since it has been live. Some home health providers find it useful and others find it to be yet another administrative burden.

Either way, the U.S. Centers for Medicare & Medicaid Services (CMS) seems intent on expanding it.

Broadly, the goal of RCD is to reduce improper billing in home health care. Illinois, Ohio, Texas, Florida and North Carolina providers have all participated at this point. An expanded implementation drew major criticism in some states, particularly during COVID-19.

Now, the worst of COVID-19 has passed, and CMS is continuing its expansion of the demonstration, this time in Oklahoma. That will start in less than a month, on Dec. 1, 2023.

“The choice selection period for Oklahoma will begin on Oct. 16, 2023, and will remain open until November 15, 2023,” Emily Richmond, who works on RCD for the Center for Program Integrity, said on a recent home health stakeholder call hosted by CMS. “Home health providers in Oklahoma can select from pre-claim review, post payment review, or a minimal post payment review with a 25% payment reduction, which means 100% of those claims have a 25% payment reduction.”

Meanwhile, the demonstration is set to expire in other states on May 31, 2024. CMS is currently considering extending it, though.

“At this time, we have the demonstration set to end in May of 2024, but CMS is currently working internally to determine if the demonstration will be extended past that May expiration date, and we will definitely provide ample notice,” Jessica Czulewicz, who also works on RCD, said during the call. “At this point, that’s about the best answer I can give.”

Multiple sources have told Home Health Care News that they believe CMS is bullish on RCD and plans to continue expanding it.

National Association for Home Care & Hospice President William A. Domi told HHCN in July that, while NAHC was generally not a big fan of demonstrations, RCD had turned out better than maybe some expected it to.

“When you look at where it was first born in Illinois, the home health agencies there went from, ‘Stop this thing’ to, … ‘We kind of like it,’” Dombi said. “It really was a 180. And not because they were flighty. But because there was a learning curve, there an operational change element to it. But in the end, once they got the organization going in terms of the paper processing, and everything else, they found the benefits were worthwhile to be able to at least feel you could sleep at night without expecting another Medicare contractor to come a year and a half later and disagree with a payment that was made, and take it back.”