CMS began enforcement of Review Choice Demonstrations (RCD) on August 3, 2020. Home health providers in North Carolina and Florida were able to select their initial choice between August 3, 2020 and August 17, 2020. Home health in all demonstration states (Illinois, Ohio, Texas, North Carolina, and Florida) with billing periods beginning on or after August 31, 2020 will be subject to review under the choice selected.
The purpose of RCD is not to create any new documentation requirements, but more so to protect against the prevalent evidence of fraud and abuse identified by CMS in home health care. Medicare coverage polices are not changing, neither are the ABN policies, claim appeal rights, and RAP processes (with the exception of PDGM changes effective 1/1/2020).
- There should be no delay in beneficiaries receiving services as services can begin prior to the submission of the pre-claim review request and continue while the decision is made.
- The pre-claim review request can be submitted for more than one episode for any single beneficiary and at any time during services.
- The claim must be submitted and reviewed with a correlating Unique Tracking Number (UTN) prior to submission of the final claim.
- A pre-claim review is not applicable for Resumptions of Care, only Start of Care and Recertification beginning the date of implementation for your State.
RCD Best Practices
Expediting the processing time from referral to submission is key with RCD. While there is no specific form required to submit, we’ve created an RCD Checklist to help you ensure accuracy of each individual submission. CMS is encouraging providers to submit the RAP and allow it to process before submitting the pre-claim review request: this will allow the beneficiary record to open in the Common Working File and will ensure you have all of the required documentation to submit with the request.
- Timely initiation of care by the home health agency
- Timely referrals to therapy
- Completion of all discipline assessments within 48 hours of admission
- Supporting documentation that add on disciplines have contacted and scheduled with the patient within 48 hours from admission.
- Any assessments outside of the 48 hours must be documented and for patient –driven reasons
- Timely completion of documentation by all clinical and office staff
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