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By way of background, close to 400 providers had their RAPs payments reduced from 60 percent to zero in the area served by Palmetto GBA. These agencies were targeted for RAP suppression because they had 100 or more RAPs auto-cancelled between January 1, 2013 and April 15, 2013.
As a result of VNAA efforts and complaints from providers, Palmetto GBA just announced that RAP suppressions are being lifted for three VNAA members that had a very low percentage of late RAPS to overall claims and were otherwise in good standing.
In a follow up letter to Palmetto on May 5, VNAA pointed out that a RAP suppression will most certainly financially cripple a nonprofit agency by withholding the funds needed to meet cash obligations including payroll and payroll tax liability. VNAA also noted that complying with Medicare law requires that home health providers withhold claims until all required documentation is obtained so providers are often in a difficult position.
VNAA argued that: 1) recent legislative and regulatory requirements (such as the face-to-face encounter and therapy assessments) have made submission more challenging and must be taken into consideration in any timetable for submission of claims; and 2) Palmetto/CMS should conduct a more intensive analysis before a RAP suppression is put in place, to ensure that only fraudulent agencies are being targeted.
Immediate Action Requested by VNAA
Given that RAP suppression has a clear and direct impact on cash flow and the ability of nonprofit providers to serve vulnerable patients, VNAA urged immediate action by Palmetto/CMS as follows:
RAP suppression should be immediately removed for agencies where number of auto-cancelled RAPs represents only a small percentage of paid claims.
Palmetto should immediately remove from RAP suppression any agency that can provide an acceptable explanation for difficulties in submitting final claims.
Special consideration should be given to agencies that serve rural areas or high risk urban areas because they may be the sole provider and because they face significant challenges in securing physician signatures
The following expedited response should be provided for the review of Corrective Action Plans:
a. Providers should receive notification by email that their plan has been received and when it will be reviewed.
b. Plans should be reviewed within 3 business days; and
c. Palmetto should send a response via email or overnight mail.
If a Corrective Action Plan is not approved, Palmetto should set up a conference call with the agency to address outstanding issues needed for an acceptable Corrective Action Plan within seven business days.
Agencies that have successfully implemented their Corrective Action Plan should be removed from RAP as soon as possible and no longer than 7 business days from the date of approval.
- Palmetto should provide each agency with a designated representative (with both an email and phone number) who is responsible for managing their case.
Longer Term Actions
In addition to the immediate actions, VNAA made some additional suggestions on future RAP suppressions including: 1) determining an acceptable rate for late submission of claims; 2) basing RAP suppression on percentage of claims; 3) sending written warning letters with clear timelines to take corrective action before any suppressions; and 4) giving additional consideration to size and location of agency and legitimate technical issues as appropriate reasons for large numbers of auto-cancelled claims.
Outreach to National and State Organizations
During this process VNAA reached out to other national organizations as well, the American Hospital Association, LeadingAge and the National Association of Home Care and Hospice (NAHC). Palmetto also conducts education and outreach program for state associations. VNAA is working to pursue ways to work with other national and state organizations to leverage influence and develop consensus on how to assist Palmetto GBA and CMS to ensure that the process of tracking down providers who are not legitimate does not harm providers who are committed to serving patients and meeting the administrative requirements.
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