Home health agencies (HHA) no longer need to submit a request for anticipated payment (RAP) to Medicare every 30 days, under new rules that took effect on January 1. Instead, HHAs will now file a one-time notice of admission (NOA) for the entire length of stay using Type of Bill (TOB) 32A, instead of a RAP for each 30-day period of care (POC).
In addition, a TOB 329 for POCs will be submitted for each 30-day claim following initial submission of the NOA. The National Uniform Billing Committee has redefined TOB 329 to represent an original claim, rather than an adjustment, for all claims with “from dates” on or after January 1, 2022.
Submitting an NOA
To submit an NOA, you must have a verbal or written order from the physician that contains the services required for the initial visit, and you must have conducted an initial visit at the start of care. For all patients with home health (HH) services continuing from 2021 to 2022, you should submit an NOA with a one-time, artificial “admission” date corresponding to the “from” date of the first period of continuing care in 2022.
The Centers for Medicare and Medicaid Services (CMS) only requires one NOA for any series of home health POCs beginning with admission to home care and ending with discharge. Once you report a discharge to Medicare, you must send a new NOA before you submit any additional claims. The NOA is a one-time submission that establishes the HH POC and covers contiguous 30-day POCs until you discharge the individual from Medicare HH services.
There will be a non-timely submission reduction in payment amount tied to any late NOA submissions when you don’t submit the NOA within five calendar days from the start of care. This is similar to the previous requirements for submission of RAPs, with penalties applying when the five calendar days submission timeframe is not met. The reduction in payment amount would be equal to a 1/30th reduction to the wage-adjusted, 30-day period payment amount for each day from the HH start of care date until the date you submit the NOA.
Requesting an exception
If you fail to send the timely NOA, you may request an exception, which, if approved, waives the consequences of late filing. The four circumstances that may qualify for an exception are:
- Fires, floods, earthquakes or other unusual events that inflict extensive damage to the HHA’s ability to operate
- An event that produces a data filing problem due to a CMS or Medicare Administrative Contractor (MAC) systems issue that is beyond your control
- You are a newly Medicare-certified HHA that is notified of that certification after the Medicare certification date, or which is awaiting its user ID from its MAC
- Other circumstances that an advisor or your MAC determines to be beyond your control
Your MAC won’t grant exceptions if:
- You can correct the NOA without waiting for Medicare systems actions
- You submit a partial NOA to fulfill the timely-filing requirement (MLN Matters: MM12256 Related CR 12256 Page 3 of 3)
- You have multiple provider identifiers and submit the identifier of a location that didn’t actually provide the service
Key points to remember
- Medicare won’t make Low-Utilization Payment Adjustment (LUPA) per-visit payments for visits that occurred on days that fall within the period of care prior to an NOA submission.
- An NOA is required for any period of care that starts on or after January 1, 2022.
- HHAs must submit the NOA when they have received the appropriate physician’s written or verbal order that contains the services required for an initial visit, and the HHA has conducted the initial visit at the start of care.
- NOA must be submitted within five calendar days from the start of care. A payment reduction applies if an HHA does not submit the NOA within this time frame. The reduction in payment amount would be equal to a 1/30th reduction to the wage-adjusted 30-day period payment amount for each day from the home health start-of-care date until the date the HHA submitted the NOA. The reduction would include any outlier payment and the amount will be displayed with value code “QF” on claim.
Patients continuing care in 2022
HHAs with periods of care that continue from 2021 into 2022 must submit an NOA with a one-time artificial admission date that corresponds with the “from” on the new period of care in 2022.
For example, if the start of care is December 13, 2021, the first 30-day period of care runs from that date through January 11, 2022. You would need an NOA on January 12 for a new period in calendar year 2022.
How Wipfli can help
Wipfli is dedicated to helping home health agencies navigate changes in the industry introduced by updated reimbursement regulations. Our experienced billing and consulting team can assist you to reduce the likelihood of penalties due to late NOA submissions by assuring that your revenue cycle management process is ready for this change. Contact us to find out how.