The Federal Fiscal Year (FFY) 2021 Home Health Medicare Maximization Services initiative is now underway. Documentation was sent for delivery via UPS on Sept. 9, 2021.

Demand Bill Directives have been sent to all Certified Home Health Agencies (CHHAs) selected to submit claims to Medicare for the first half of the FFY 2021 Home Health Medicare Maximization Services initiative. The Episodic Payment System (EPS) claims selected for this initiative fall between Oct. 1, 2020 and March 31, 2021, or until the end of the episodic period billed to Medicaid.

On Jan. 1, 2021, the Centers for Medicare and Medicaid Services (CMS) implemented a new Medicare billing requirement for Home Health Agencies (HHAs) requiring a No-Pay Request for Anticipated Payment (No-Pay RAP). This change requires that a No-Pay RAP submission be submitted to Medicare for dual-eligible Medicare/Medicaid recipient claims regardless of whether the final claim is intended to be billed to Medicare. The Office of the Medicaid Inspector General (OMIG) has provided further guidance pertaining to this CMS billing requirement and the impact to the Medicaid program/Demand Bill Directive in the New Billing Requirement for Home Health Agencies: Demand Billing, No-Pay RAP section of the August 2021 New York State Medicaid Update.

The Medicaid Update states the following:

The dates of service included in the upcoming review period overlap with the start of the new CMS No-Pay RAP billing requirements. HHAs should have initiated a No-Pay RAP prior to receipt of the Demand Bill Notice. If the No-Pay RAP was not submitted in compliance with the new Medicare billing requirement for any period of care on the Demand Bill Directive, the HHA should take the following three steps:

1. submit a No-Pay RAP to CMS for all identified dates of service,
2. file a Demand Bill final claim with a KX modifier and indicate within the Remarks section of the claim "late RAP due to Medicaid TPL demand billing request", and
3. follow all outlined instructions within the Demand Bill Directive pertaining to timely and complete submission of information and documentation to UMass.

CMS is allowing the above steps as a temporary fix for the submission of demand bills for which No-Pay RAPs were not previously submitted.

All questions regarding demand billing should be directed to UMass at 866-626-7594.

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