CMS Makes Change in Manual for Request for Anticipated Payments

The Centers for Medicare and Medicaid Services (CMS) recently released Transmittal 10254 entitled “Penalty for Delayed Request for Anticipated Payment (RAP) Submission – Implementation.” This document updates Chapters 3 and 10 of the Medicare Claims Processing Manual with instructions to Medicare Administrative Contractors (MACs) and providers for the generation and processing of the no-pay RAP that is to be implemented on Jan. 1, 2021.

Per changes made in the 2019 and 2020 Home Health Prospective Payment System (HH PPS) final rules, CMS is implementing the final phase-out of RAPs. For all periods of care with “from” dates on or after Jan. 1, 2021, Medicare will no longer make payment on RAPs, though RAP submission is still required for periods of care other than No-RAP Low Utilization Payment Adjustments (LUPAs). CMS considers all RAPs for periods of care beginning on and after Jan. 1, 2021 to be paid 0 percent.

A timely-filed RAP is submitted to the home health MAC and accepted by that MAC within five calendar days after the “from” date of a home health period of care, though posting to the Common Working File (CWF) system may not occur within that same time frame. The date of posting to the CWF is not a reflection of whether the RAP is considered timely-filed.

In instances where a RAP is not timely-filed, Medicare will reduce the payment for a period of care, including the outlier payment, by the number of days between the home health “from” date and the date the RAP is submitted/accepted by the MAC divided by 30.

No LUPA per-visit payments shall be made for visits that occurred on days that fall within the period of care prior to the submission of the RAP.

If an agency fails to file a timely RAP, it may request an exception which, if approved, waives the consequences of late filing. The transmittal defines four such circumstances that may qualify for an exception, including unusual events that may have inflicted damage on an agency’s ability to operate, a CMS or MAC systems issue beyond the provider’s control, certain timing circumstances for newly certified agencies, and other occasions.

Contact: Meg Everett, meverett@leadingageny.org, 518-929-9342