3 No-Pay RAP Issues and What to Do About Them 

Situation Report | February 8, 2021

During a recent forum, the U.S. Centers for Medicare and Medicaid Services (CMS) provided an update on three claims-processing issues related to the no-pay Requests for Anticipated Payment (RAP) in 2021.

Value Code 61

No-pay RAPs are being returned to provider (RTP’d) for not having value code 61 and the core-based statistical area (CBSA) code even though these elements are optional on RAPs beginning January 1, 2021.

As HCA previously reported, Medicare Administrative Contractors have been instructed to add value code 61 and a placeholder CBSA code 10180 to the RAP so it can continue to process.

However, for RAPs that were RTP’d before this workaround, Certified Home Health Agencies (CHHAs) concerned that the RAP may have been recorded as late can apply for an exception to the penalty describing the system error. 

Reason Code W7216

No-pay RAPs are being RTP’d incorrectly with reason code W7216 indicating an invalid line-item date with revenue code 0023 when the date falls outside of the “from” and “through” date. Until this issue is resolved MACs will suspend the RAP in status/location SMWRAP and bypass the edit for the RAP to process. 

CHHAs concerned that the RAP may have been recorded as a late submission before these errors were identified should apply for an exception to the penalty describing the circumstances beyond the CHHA’s control. 

Incorrect Late Submission Penalties

The late submission penalty is incorrectly being applied to RAPs submitted earlier than 5 days of the “from” date. This error impacts RAPs for the second 30-day period where CHHAs are permitted to submit the RAPs early. A system fix will not be installed until March 1, 2021. Therefore, CHHAs might want to wait to submit claims until after the fix is installed to avoid an incorrect penalty.

However, once the fix is implemented, the MACs shall adjust no-pay RAPs with a value code QF amount greater than $0 (penalty amount) and RAP receipt date of more than five days earlier than the “from” date. CHHAs may still submit RAPs as they choose. National Government Services (NGS) says it will provide updates when additional news becomes available.