Surviving the Review Choice Demonstration by The Home Health Agencies

Review Choice Demonstration or RCD has somewhat restricted the ‘upper hand’ attitude of the home health care agencies since its launch. It is supposedly the most dreaded regulatory measure imposed by the CMS that requires these agencies to have quality documentation procedures in place. In addition to that it also requires a strong Electronic Medical Record or EMR partner. These are the keys that will help the home health care service providers to survive the upcoming demo. Moreover, the experts caution that if RCD is successful then it will also be very critical for the home health care agencies to pick the right claims review option.

  • This means that when it comes to the aspect of having good processes in place it should be the ones that will assure that the staffs willing to buy into what the care receiver is trying to accomplish.
  • On the other hand when it comes to having a strong EMR it is required by the home care agency to have one that will adapt to all different regulatory changes very quickly so that there is not lagging behind.

RCD was announced last May by the Centers for Medicare and Medicaid Services or CMS which is actually a modified version of the failed Pre-Claim Review Demonstration or PCRD that was formulated and implemented in 2016.

  • Much unlike PCRD the RCD does not have any procedural issues or other hurdles.
  • Similar to PCRD the RCD is meant to contest improper home health Medicare billing.

According to statistics provided by the Government Accountability Office or GAO, the improper home health Medicare billing totaled to $3.2 billion in 2018.

The features of RCD

Unlike the old PCRD demo the RCD has better features and options for the home care agencies.

  • One such is that it provided the home health agencies with several different options so as to decide how they can and are willing to participate.
  • Under the RCD the home health care agencies are allowed to pick one between pre-claim or post-payment review paths. This is in addition to the option for a minimum review that comes with a typical 25% payment reduction.
  • Moreover, the home health care agencies that have proven track records or those agencies that realize a claims affirmation rate of more than 90% are also allowed to choose from a unique and selective post-payment review option or less-extensive spot check.

It is expected that such demonstration will help to keep the dollars in the Medicare program and prevent the unscrupulous home health care providers who are out there to make fast and easy money from accessing it.

Choosing the right path

Initially, only the newly initiated episodes of home health care will be taken into consideration and will be subject to the demo requirements. This will be applicable to all home health care providers and therefore those who did not make any changes in their processes from the first Pre-Claim Review Demonstration now will need to shift into RCD for sure especially if they choose the pre-claim review option.

  • It is said that home health care service will be smoother and better with RCD for the first time around.
  • However, as from the perspective of the home health care agencies, they will not like to be the subject to the demonstration simply due to the fact that RCD will take additional time to process irrespective of which option is chosen by the health care agencies.

When it comes to picking the right path you must first know that more that 77% of home health care providers are already working with RCD choosing the full pre-claim review option.

According to Illinois Home Care & Hospice Council, IHHC many of the home health care providers are eligible for the ensuing set of choices simply due to their strong compliance. About 22% of health care providers have already chosen the 5% spot check option. However, there seems to be very few takers of the minimal review option with a payment reduction.

They suggest that there are several reasons why the home health care providers choose the pre-claim review so overwhelmingly.

  • One of the biggest reason being the ability of these health care agencies to make the necessary changes to the potentially problematic claims early on.
  • Another reason could be the fact that up-front affirmation means that the agency is most likely to get paid.

Moreover, it is included in the Bipartisan Budget Act of 1997 that any agency with a CAH designation must be designed to decrease the financial susceptibility of rural hospitals. It must also have improved access to health care and maintain and provide essential health care services in rural communities. In order to do so the designated CAHs will receive special benefits such as cost based recompense for Medicare services to encourage them to go on.

When you choose the pre-claim review you will also have the opportunity to fix any issues but if you choose spot check option you can only make an additional development request but there will be no scope for any fixing. You will have to submit the entire record and CMS will have the opportunity to review that complete and detailed record. Period!

Future of RCD

No matter how strongly RCD comes into effect that is a lot of uncertainty of the enforcement of RCD in specific states.

Initially slated for a June 1 release in the state of Illinois, CMS plans to expand this demo into Ohio, Florida, North Carolina and Texas as well. However, it is unclear as to which states will follow the Prairie State. Few industry experts suggest that CMS will introduce it in Texas last because of the market size of home health there.

However, all are expecting to have a smooth transition into RCD and also hope that any issues that may arise will be addressed quickly. After all it is the health of the people especially the older citizens are in question as well as the survival of the home health care industry.

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