Situation Report | August 2, 2021
The U.S. Centers for Medicare and Medicaid Services (CMS) recently posted Change Request 12227 on Medicare system changes to implement the processing of Notices of Admission (NOAs) and claims beginning on and after January 1, 2022.
NOAs will be submitted using type of bill (TOB) 32A and may be cancelled using TOB 032D. All claims for periods of care following the admission will be submitted using TOB 329.
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. This redefinition allows home health agencies (HHAs) to continue using the TOB 329 even with the elimination of Requests for Anticipated Payment (RAPs) and the move toward NOAs.
As with the no-pay RAP, the NOA submission criteria will require HHAs having a verbal or written order from the physician that contains the services required for the initial visit, and that the HHA has conducted an initial visit at the start of care. There will be a non-timely submission reduction in payment amount tied to any late submission of NOAs when the HHA does not submit the NOA within 5 calendar days from the start of care. 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.
Section 12227.1.4 of the Change Request includes the following data elements required for NOAs using TOB 032A or 032D:
- Statement From/Through Dates
- Patient’s Name
- Patient’s Date of Birth
- Patient’s Gender
- Patient’s MBI
- Admission Date
- HHA Provider Identifier (NPI)
CMS plans to issue a separate Change Request to update the Medicare Claims Processing Manual with detailed NOA submission instructions and revised billing instructions.