Another No-Pay RAP Issue Involving Date Mismatch

Situation Report | March 1, 2021

Beginning January 1, 2021, the U.S. Centers for Medicare and Medicaid Services (CMS) implemented the new no-pay Request for Anticipated Payment (RAP) policy that has resulted in many glitches for Certified Home Health Agencies (CHHAs) across the nation. 

Some of the glitches have been caused by CMS claims-processing system issues that HCA recently summarized for members in the February 8 Situation Report, including how CHHAs can avoid potential payment penalties for not submitting the no-pay RAP timely.  

More recently, our colleagues at the National Association for Home Care and Hospice (NAHC) have identified the another no-pay RAP issue which has been causing many problems for CHHAs. 

Home Health Prospective Payment System (HHPPS) final claims are not processing for many CHHAs when the date for revenue code line 0023 on the no-pay RAP does not match the date on line 0023 on the final claim. The two Reason Codes associated with the date mismatch are 38107 and U5391.   

CMS confirmed for NAHC that the instructions permit line 0023 on RAPs for subsequent periods to be the first date of the period in order to assure timely submission of RAPs; however, line 0023 on the claim must match that date. CMS permits the actual first visit date to be different than line 0023 on the claim, but line 0023 on the RAP and claim must always match.  

Much of the confusion relates to the instructions in the Medicare Claims Processing Manual, chapter 10, section 40.2, that reads: “For subsequent episodes, the HHA reports on the 0023 revenue code the date of the first visit provided during the episode/period, regardless of whether the visit was covered or non-covered.”  

Agencies will need to correct line 0023 on the claim to match the RAP in order for claims with reason codes 38107 and U5391 to process. 

The implementation no-pay RAPs has been problematic for many CHHAs across the country. HCA CHHA members are encouraged to monitor closely the status of final claims and no-pay RAPs. CHHAs are encouraged to submit the no-pay RAP as soon as possible so that agencies have time to act and avoid a penalty when a claim or RAP does get returned to provider (RTP’d). However, if no-pay RAPs are being returned due to glitches with CMS’s Medicare systems, then CMS and NGS have said they will make sure impacted CHHAs are not subject to the five-day penalty and will be given instructions on how to proceed to avoid it.