NAHC Addresses RAP Suppression with Palmetto GBA
April 29, 2013 04:46 PM
Palmetto GBA, the largest home health and hospice Medicare Administrative Contractor (MAC) took steps last week to suppress payments to home health agencies identified as having a “high number” of auto-cancelled Requests for Anticipated Payment (RAP). At this time, Palmetto plans to suppress RAP payments for any home health agency that had 100 or more RAPs auto-cancelled between January 1 and April 15, 2013 (See NAHC Report, April 23, 2013).
In response to calls for assistance from its members, the National Association for Home Care and Hospice (NAHC) contacted Palmetto to discuss this action and identify steps home health agencies should take to be removed from RAP suppression. NAHC pointed out that Medicare’s authority to suppress RAP payments is based on program integrity, and therefore RAP payment suppression should be limited to cases where fraud or abuse is suspected. NAHC suggested that Palmetto carry out a second level of information analysis before suppressing RAP payments based simply a number of cancelled RAPs in order to ensure that only agencies that are suspected of fraudulent or abusive practices are having their payments suppressed.
On its website, Palmetto identified steps that home health agencies should take to have their RAP payment suppression lifted. This includes submission of a Corrective Action Plan to Palmetto as follows:
When submitting the Corrective Action Plan, it should include a statement of the problem or weakness that caused the delay in filing final claims, include proposed solutions to the problem, and state who is responsible for the monitoring the CAP. Palmetto GBA will review each CAP on a case-by-case basis depending on the provider-specific circumstances. If an agency believes they were timely in filing final claims, or has a rationale for the number of cancelled RAPs, they can send a rebuttal to the fax number listed in the letter (803-462-2659). In the rebuttal they can identify the reason(s) the RAPs cancelled and the number of RAPs affected. Any salient information is useful.
According to a representative, Palmetto will review all Corrective Action Plans promptly and send recommendations to the Centers for Medicare & Medicaid Services (CMS) for final approval or rejection.
During correspondence with Palmetto, NAHC pressed for consideration of any legitimate reasons an agency has for a large number of auto-cancelled RAPs – such as unsuccessful efforts to get orders/F2F signed, temporary staffing problem during the first quarter, new software or software problems. NAHC emphasized that immediate removal from RAP suppression should be considered for agencies where 100 auto-cancelled RAPs represent a small percentage of paid claims. NAHC also recommended that an edit be based on the percentage of auto-cancelled RAPs - the greater of 25 auto-cancelled RAPs in a month or 25% of total RAPs in the period - for consideration.
NAHC further suggested that any agency that can provide an acceptable explanation for failure to submit final claims should have immediate removal from RAP suppression. Finally, NAHC recommended the timeline for evaluation of successful implementation of an agency corrective action plan be carried out in no more than one month, rather than three months as stated in the letters.
In review of reasons offered by NAHC for high numbers of auto-cancelled RAPs, Palmetto did raise an objection to unsuccessful efforts to secure physician signatures alone as acceptable, pointing out that all agencies must comply with this requirement. However, any reasonable explanation submitted with a Corrective Action Plan will be considered if accompanied by supporting evidence.
Palmetto acknowledged that they will consider adopting refinements to the RAP suppression project in future months, with agency size as a definite consideration. Palmetto also admitted that they are still refining efforts to look for final claims. In response to a NAHC request to provide pre-suppression opportunities to submit an explanation for the volume of auto-cancelled RAPs, Palmetto pointed to the warning letters that are being sent to agencies with 50-99 auto-cancelled RAPS as a step in that direction. The organization also responded to NAHC’s recommendation for evaluating the restoration of RAP privileges on a monthly basis, saying that they will evaluate agencies’ performance as they go along, and if there is legitimate improvement will recommend removing RAP suppression short of 3 months.
Home Health Agency Responses
Home health agencies must first determine whether Palmetto’s findings are correct, and rebut if incorrect. Agencies that have a high number of auto-cancelled RAPs should develop a plan of correction that includes documented evidence of reasons why they were unable to submit final claims timely. Also, if the majority of their auto-cancelled RAP episodes eventually result in a final claim payment, this data should be included. Large agencies should include evidence that the percent of RAPS being auto-cancelled is small and that suppression of RAP payment is unjustified in their case. The analysis of cause - with supporting evidence - and corrective action plans should be sent by fax to Palmetto as soon as possible. Finally, evidence of financial hardship resulting from RAP payment suppression should be included.
NAHC also recommends that home health agencies monitor their outstanding RAPS and, if they believe they will be unable to submit the final claim before the 120 days, they should cancel those RAPs before they are auto-cancelled.