Last week, the Centers for Medicare and Medicaid Services (CMS) announced major updates to the Pre-Claim Review Demonstration (PCRD) and the Home Health Conditions of Participation (CoPs).
Pre-Claim Review Demonstration Paused In Illinois & Delayed In Florida
On March 31, 2017, one day before PCRD was set to begin in Florida, CMS announced:
“As of April 1, 2017, the Pre-Claim Review demonstration will be paused for at least 30 days in Illinois. The demonstration will not expand to Florida on April 1, 2017.
After March 31, 2017, and continuing throughout the pause, the Medicare Administrative Contractors will not accept any Pre-Claim Review requests. During the pause, home health claims can be submitted for payment and will be paid under normal claim processing rules. CMS will notify providers at least 30 days in advance via an update to this website of further developments related to the demonstration.”
According to industry publications and national associations, PCR may become optional for home health agencies and those HHAs who use PCR will be exempted from the risks of post-pay review absent any indications of fraud. Furthermore, CMS intends to reform PCR to a more targeted approach that “Focuses on the first episode of care, certain diagnoses, and HHAs that do not demonstrate a sufficient level of compliance performance,” according to NAHC.
Delay In New 2017 Home Health CoPs
Instead of going to effect on July 13, 2017, the new CoPs have been delayed by 6 months and are now scheduled to go into effect on January 13, 2018, under a proposed rule issued by CMS last Friday. The proposed rule is subject to a 60-day public comment period, following its publication in the Federal Register, scheduled for April 3rd.
Please see our previous two posts to learn more about the new CoPs.