6 NOA submission requirements to consider before 2022

Dwelling well being companies are arising on the ultimate section of PDGM. And whereas it might appear to be yet one more administrative burden, this ultimate replace will doubtless be a welcome change to your company. RAPs will probably be phased out, and residential well being companies will revert to the one-claim-per-patient-per-month idea—often called the Discover of Admission (NOA). Do you absolutely perceive how this transition will have an effect on your billing and assessment processes?

By: Brandy Shifteh

In our latest webinar, Embracing PDGM’s ultimate section advantages of NOA, trade specialists mentioned classes discovered from No-Pay RAPs and what to anticipate with new discover of admission (NOA) rules.

Whereas we’ve discovered that the No-Pay RAP course of has resulted in penalties from late billing, pricey results from inefficient staffing, and time-consuming exception requests, the NOA implementation will include its personal set of compliance and regulation issues.

Right here, we’ll talk about six NOA submission necessities to think about for when it turns into efficient on January 1, 2022. A few of this may occasionally sound acquainted, as most of the insurance policies mirror present No-Pay RAP rules.

What’s the admission interval?

Primarily new language for a brand new requirement, the house well being admission interval is a claims processing idea used to appropriately implement major residence well being company assignments, and to set off consolidated billing edits. CMS defines it because the interval between the from date of an NOA and the discharge date.

An admission interval can include a number of 30-day intervals of care and their corresponding claims up till the purpose that the affected person is discharged. If the affected person had been then to be readmitted, a brand new NOA could be required inside 5 days of that new begin of care.

Understanding NOA submissions

Whereas residence well being companies will now not be required to submit No-Pay RAPs for any interval of care with a from date on or after January 1, 2022, they may as a substitute notify Medicare programs through submission of an NOA for every admission. This NOA should be submitted inside 5 calendar days of the admission, simply as the present No-Pay RAP requirement.

Submitted utilizing invoice 32A, the NOA opens the primary interval of care and establishes the first residence well being company and triggers consolidated billing edits. Invoice 329 can then be used for claims for intervals of care following the submission of your preliminary NOA.

Non-timely submission discount in cost

If an NOA submission is late—not submitted inside 5 calendar days from begin of care—companies will probably be penalized with a 1/30 discount to the wage-adjusted 30-day interval cost quantity for every day from the beginning of care till the NOA submission date.

Simply as with No-Pay RAP penalties, this cost discount will be important. For those who submit the NOA on day six, that may equate to a 20% cost discount, which continues to extend with every late day. Remember the fact that the beginning of care date is taken into account day zero, and cost reductions are the supplier’s legal responsibility.

Distinctive circumstances

There are exceptions that may waive the implications of late filings, however the residence well being company should present enough info within the remarks part of their declare to permit the MACs to analysis the case. If these remarks should not enough, the MAC will request extra documentation, which is why it’s essential to maintain paperwork that help proof of well timed submission—together with display pictures, Medicare system screens, and related printouts.

CMS particularly calls out three circumstances for which the MACs is not going to grant exception to
the cost discount:

  • If the company can appropriate the NOA with out ready for the Medicare system’s actions
  • If the company submits a partial or incomplete NOA to meet the well timed requirement
  • If the company with a number of supplier identifiers submits the identifier of a location that didn’t present the service

CMS has clarified {that a} partial NOA could be a submission that’s lacking required fields or has invalid values in these fields.

Medicare secondary payers and modifications to unique Medicare

If the affected person has an MSP recognized in the beginning of care, the NOA must be submitted, no matter whether or not the MSP is major or not. When a affected person’s payer modifications to unique Medicare, a brand new begin of care OASIS should be accomplished that displays the date of the beneficiary’s change to unique Medicare.

Whereas this isn’t a brand new requirement, it’s necessary to keep in mind that the five-day submission requirement does apply for payer modifications to unique Medicare. Nonetheless, it you had no method to know as a consequence of circumstances out of your management, an exception must be requested.

Medicare Benefit payers

Billing and documentation necessities differ by MA plan, so residence well being companies want to succeed in out to their contracted MA plans and begin validating what these billing and documentation necessities will probably be in 2022. Shifting ahead, we advocate validating contracted MA plans yearly as a part of your contract assessment course of, and validating billing necessities as a greatest follow on the level of consumption.

Navigating the unknown

Because the trade continues to research the present guide directions for submitting the NOA, gaps and questions are being recognized that require clarification and steerage from CMS. Quickly in 2021, count on to see an extra “hole filler transmittal” that may present additional steerage, notably because it pertains to switch and discharge situations inflicting confusion within the present state of No-Pay RAP.

To be taught extra about upcoming NOA necessities and the best way to greatest put together your company for compliance, request a session within the kind on this web page.

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