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Review Choice Demonstration for Home Health Services

Update 4/3/2019:

The Centers for Medicare & Medicaid Services (CMS) received Paperwork Reduction Act (PRA) approval for the Review Choice Demonstration for Home Health Services (the demonstration).  The Office of Management and Budget (OMB) has reviewed the demonstration documents and CMS’ responses to public comments and approved the collection of information. The updated online status is available here.

In response to public comments, the demonstration incorporates more flexibility and choice for providers, as well as risk-based changes to reduce burden on providers demonstrating compliance with Medicare home health policies. HHAs will select from three initial choices:

  • Pre-claim review,
  • Postpayment review, or
  • Minimal postpayment review with a 25% payment reduction. 

After a 6-month period, HHAs demonstrating compliance with Medicare rules through pre-claim review or postpayment review will have additional choices, including relief from most reviews except for a review of a small sample of claims. Illinois HHAs that previously participated in the initial Pre-Claim Review Demonstration for Home Health Services and met the 90 percent target full provisional affirmation rate (based on a minimum 10 requests submitted from August 2016 through March 2017) can begin the demonstration by selecting from the additional choices. Full demonstration details will be available in the Operational Guide published in the ‘Downloads’ section below.

The choice selection period for HHAs located in Illinois will begin on April 17, 2019 and end on May 16, 2019.  HHAs should visit the Palmetto GBA provider portal here for information and instructions on the selection process.  Beginning April 17, 2019, HHAs will be able to view their available choices and make their selection through the portal.  Palmetto GBA will also send letters to all Illinois HHAs detailing this information; however, HHAs do not need to wait to receive their letter and may go to the provider portal starting on April 17, 2019.  HHAs that do not make a choice selection by May 16, 2019 will be automatically placed in Choice 2: Postpayment Review. Following the close of the choice selection period, the demonstration will begin in Illinois on June 1, 2019, and all episodes of care starting on or after this date will be subject to the requirements of the choice selected. 

With this demonstration’s approval, CMS is better positioned to identify and prevent fraud, protect beneficiaries from harm, and safeguard taxpayer dollars to empower patients while minimizing unnecessary provider burden. The demonstration helps ensure that the right payments are made at the right time for home health service through either pre-claim, prepayment, or postpayment review, protects Medicare funding from improper payments, reduces the number of Medicare appeals, and improves provider compliance with Medicare program requirements. The demonstration should not delay care to Medicare beneficiaries and does not alter the Medicare home health benefit. The demonstration will not create new clinical documentation requirements. HHAs will submit the same information they are currently required to maintain for payment.  

CMS will continue to post updated information on this website. In addition, CMS and Palmetto GBA will provide at least 60 days’ notice before the choice selection period starts in each of the additional four states. CMS will provide notice on this website before phasing in the other demonstration states: Ohio, Texas, North Carolina, and Florida. Please send any questions to: homehealthRCD@cms.hhs.gov.

Background

On April 1, 2017, CMS paused the Pre-Claim Review Demonstration for Home Health Services to consider a number of changes in response to stakeholder feedback. On May 29, 2018, CMS first announced our intention to implement the Review Choice Demonstration for Home Health Services through a PRA notice and sought initial public comments. On September 27, 2018, CMS published responses to initial comments and a subsequent PRA notice, and provided the public another opportunity to comment on CMS’ efforts to collect information on the revised demonstration. The second public comment period ended October 29, 2018. The published responses and additional information on the demonstration design are available here.