CMS Revises Instructions for Submission of No-Pay RAP   

Situation Report | October 5, 2020

The U.S. Centers for Medicare and Medicaid Services (CMS) recently revised Change Request (CR) 11855 to update the service date reporting on the claim and some remarks.

Shortly after CMS issued the original CR, our colleagues at the National Association for Home Care and Hospice (NAHC) asked CMS exactly how a home health agency (HHA) should document on the claim those situations where a date could not be entered on line 0023 (the date of the first visit of the 30-day billing period) because the first visit did not occur within the first five days of the period. CMS responded that in these situations the HHA may enter the first day of the period of care as the service date on this line when submitting a RAP for a subsequent period of care. This will prevent delaying the submission of the RAP for subsequent periods when the first visit in that period would be beyond the 5-day timeframe for a timely-filed RAP and will allow for the submission of RAPs for two 30-day periods of care immediately after the start of a 60-day certification period.

If the RAP that corresponds to a claim was filed late and the HHA is requesting an exception to the late-filing penalty, the HHA should enter information supporting the exception category that applied to the RAP.

CR 11855 was updated to reflect that if the RAP that corresponds to a claim was originally received timely but the RAP was canceled and resubmitted to correct an error, the HHA enters remarks to indicate this condition (e.g., “Timely RAP, cancel and rebill”). The HHA is to append modifier KX to the HIPPS code reported on the revenue code 0023 line. HHAs should resubmit corrected RAPs promptly (generally within two business days of canceling the original RAP). Remarks are otherwise required only in cases where the claim is cancelled or adjusted.