The Centers for Medicare & Medicaid Services (CMS) has been tight-lipped about its Review Choice Demonstration (RCD) plans beyond May 2024.
However, industry leaders believe RCD will be extended across the country on a more permanent basis — a development that agency leaders should recognize as a momentum shifting change.
“We’re seeing a monumental shift in home health care and how we actually operate,” Kim Gaffey, founder and CEO of Gaffey Home Nursing and Hospice, said during a webinar Thursday. “When we started RCD five years ago, we really had three silos inside our business: clinical, billing and administrative. Oftentimes those three silos worked somewhat independently. As we entered into this RCD world, we had to bring all three silos together and examine how they interacted with each other.”
The Illinois-based Gaffey Home Nursing and Hospice offers home health, home nursing and hospice services.
Generally, RCD requires home health care providers to submit claims documentation earlier on in the care process and is meant to target and combat fraud in the industry. CMS’ goal in RCD is to reduce improper billing under Medicare’s home health benefit.
In 2017, lawmakers successfully blocked the expansion of the Pre-Claim Review Demonstration (PCRD) — the precursor to RCD. The original iteration got off to a rocky start in Illinois, with providers and associations complaining of administrative burden, compliance costs and high non-affirmation rates.
A few years later, RCD was introduced in five states: Illinois, Ohio, Texas, North Carolina and Florida. CMS suspended the demonstration in late March of 2020 due to the COVID-19 crisis, but soon after announced that it would resume in August, much to the chagrin of providers in those states.
A year later, CMS made a major change to the way billing was processed, which was a reprieve for providers. Today, those providers are reflecting on how those changes have affected the way they do business.
“One of the first things that you realize once you’re in the RCD system is how many times each one of those silos touch the document or communicate with the provider,” Gaffey said. “From the first day of patient interaction to the final day of billing, we’re seeing that we are now a team instead of three independent departments. Without implementing and examining that process, you’ll fail at RCD.”
Because a premium is put on accuracy and communication in the documentation process of RCD, there are a lot of positives that come with the time consuming aspects of the program.
“I think it’s had such a positive impact on home care, especially when it comes to documentation accuracy,” Michelle Mullins, COO of HealthRev Partners, said during the webinar. “That accuracy in itself has had such a positive domino effect. Coding services is a perfect example. That clinical documentation has been enhanced not only in the assessment summary process, but it’s also driven the ability to code more accurately. If you can code more accurately, you ultimately have a cleaner claim and allows you to submit your claim faster on the back end.”
HealthRev Partners is a health care revenue cycle management company that works with home health providers.
The RCD program also reduces the risk of audits and penalties, Mullins said.
Providers tend to agree that it takes time getting used to RCD, but getting used to it is plausible.
“Documentation at the front end and education are really the key components,” Stephanie Henchey, VP of operations at the Florida-based Concierge Homecare, said during the webinar. “If you don’t have that documentation at the very beginning and you don’t have the sophistication of a sales team that can articulate what’s really needed, it slows your process down. Building off of those KPIs is incredibly important to know which phase takes how long and where you can tighten up that timeframe. You are working in a much tighter window.”