Request for anticipated payment (RAP) was replaced by Notice of Admission (NOA). It started on January 1st, 2022. Within 5 days of start of care, home health agencies should submit a NOA to Medicare admirative contractor or they would be subjected to a non-timely submission fee. It is a one-time notification for series of home health periods of care, also known as HHPCOS, which is basically an extension to no-pay RAPs and goes back to the older version of reduced RAPs in 2020. Similarly, as it was, the penalty for non-timely submissions of RAPs, Medicare providers will be penalized in the cases of non-submission of NOA within 5 days from the start of the care. Same penalties shall apply for late submission of NOAs, similar to RAPs.
Purpose of NOA
NOA is simply a proof or a notification that patient care would be provided by the submitting HHA and would remain active until the patient discharges. In case additional files claims need to be submitted the HHA must submit a new NOA.
How to Avoid the Penalty
Home Health Care agencies are not responsible for late NOA fillings if anything has been delayed due to unforeseen circumstances. Here are a few examples of the same listed by CMS:
- Act of God or Extensive Damage which cannot be operated on the level of HHAs (Home Healthcare Agencies) abilities.
- Any Data filing issues or system faults beyond the control of HHA.
- And all the other circumstances which cannot be controlled up to the abilities of HHA.
How to File a NOA
Dating from January 1st, 2022, NOA should be filed for every patient with an admission date with the first date of service. The HHA, should submit one NOA at the start of admission period. It is effective till the discharge period even if a patient is discharged and re admitted NOAs should be filed. The NOA’s validation depends upon the HHA’s written or verbal physician’s order.
How to Submit a NOA
A NOA should be submitted to A/P MAC HHA, and this would be accepted by MAC during the 5 calendar days of duration. One can submit the NOA through the EMR or DDE directly.
The NOA establishes the patient and stay active till the discharge of the patient is submitted. For any additional claims after the discharge of the patient is submitted to Medicare a HHA must submit a NOA in order to send and receive payments for any additional claims.
A NOA requires only two pieces of information
- Written or verbal doctors order which identifies the skills required.
- Completion of the first visit.
In the new No-pay rap guidelines the NOA eliminates the requirement to submit a valid HIPSS code and diagnosis code, even if the patient’s primary insurance is not medicare it is recommended to still submit a NOA.
One rule of thumb that must be followed by all home health care agencies is to always submit NOA so that it is on file with Medicare. In case the payer is changed the care is already established with medicare and this would help to release the final claim.
In case the patient’s primary insurance with medicare then OASIS documentation is also required.
Who are expecting a NOA?
Patients with medicare insurance are the only payers requiring a NOA. Yet, it is always considered the best practice for HHAs to submit NOA for all patients as this will ensure that one is on file with medicare in case the payer changes or if HHA needs to file additional claims.
The billers must be vigilant when it comes to Medicare Advantage (MA) plans as some require NOAs for reimbursement It is advised to contact each MA contractor for more on the requirements.
The impact of new guidelines for No pay RAPs
The intent for the new guidelines by CMS is to simplify the entire ordeal and provide agencies with a straightforward administrative process the biggest change between the old and new guidelines is that valid HIPSS code and diagnosis code are no longer required, the only requirement is the order for service and completion of the first visit to submit NOA.
As mentioned above the CMS requires only one NOA for any series of HH POCs starting with admission in a HHA and ending with discharge of the patient from the HHA.
When it comes to improper submission of NOA penalties will be applied. For example, if a NOA is not filed until day 45 the penalty is for 45 days which the agencies should be aware of. Compared to the No pay Raps the NOA penalties are severe.