Palmetto GBA, MAC Suppressing RAP Payments
Tuesday, April 30, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy




VNAA is aware that that Palmetto GBA, Jurisdiction 11 Medicare Administrative Contractor (MAC), has taken action to suppress payments to home health agencies with a “high number” of auto-cancelled Requests for Anticipated Payment (RAP). According to Palmetto, these RAPs are being suppressed because the targeted agencies failed to submit final claims in the specified time period, which resulted in RAPs being auto-cancelled between January and April 2013.

If your agency received either a RAP suppression letter or a warning letter that you could be subject to RAP suppression, please send an email to kbarnett@vnaa.org. All communications to VNAA will be maintained with strict confidentiality. The goal is to determine how many VNAA members have been impacted. VNAA is currently working on a letter with member input to send to the Centers for Medicare and Medicaid Services and Palmetto GBA.
 
A bulletin released by Palmetto GBA April 18 states that “Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim. If the final claim is not submitted within the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim.”
 
For the targeted home health agencies, RAPs will be set at zero percent according to Palmetto GBA. Further, this suppression will continue until the provider submits a Corrective Action Plan and can demonstrate improvements in timely billing of their final claims. Providers have 90 days to submit the Corrective Action Plan.

In addition to letters informing some providers that they are subject to RAP suppression, warning letters are also being sent to other agencies notifying them that their “current billing practices are unacceptable and their RAPs are being monitored. If improvement is not noted within a reasonable amount of time, future RAPs may be set to pay at zero percent.”
 
As of this moment, Palmetto GBA is the only home health and hospice MAC suppressing RAP payments. However, all MACs have the authority to suppress RAPs according to Medicare Regulations. Palmetto GBA has home health and hospice claims administration responsibilities for workload in Alabama, Arkansas, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Mississippi, New Mexico, North Carolina, Ohio, Oklahoma, South Carolina, Tennessee and Texas.
 
Below is the bulletin notice from Palmetto GBA:
 
Home Health Request for Anticipated Payment (RAP) and Submission of the Corresponding Final Claim
 
Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim. If the final claim is not submitted within the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim. It is expected that instances where the RAP is auto-cancelled for no submission of a final claim should be minimal.

Palmetto GBA is monitoring the number of RAPs that are auto-cancelled due to providers not filing a final claim. In accordance with Medicare regulations, contractors have the authority to revoke a provider’s privilege to receive payment on the RAP. Therefore, providers identified with a high number of RAP auto-cancels due to no final claim will be notified that their RAPs will be set to pay at zero percent. The payment suppression will continue until a Corrective Action Plan is submitted and the provider can demonstrate improvement in timely billing of final claims. We will not be withholding the RAP payment, we will simply not pay RAPs for these aberrant providers. The affected providers will only be paid for final claims.

Other providers that are identified to have RAPs auto-cancelled for no final claims that are below the acceptable threshold will be notified that their current billing practices are unacceptable and their RAPs are being monitored. If improvement is not noted within a reasonable amount of time, future RAPs may be set to pay at zero percent.

Reference: CMS Internet Only Manual (IOM), Publication 100-04, Chapter 10, Section 10.1.12
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