Effective March 29, 2020, certain claims processing for the Review Choice Demonstration (“RCD”) for Home Health Services were paused in Illinois, Ohio, and Texas, because of the COVID-19 pandemic. During the pause, home health claims submitted on or after March 29, 2020, were not to be subject to the review choices made by home health agencies under the demonstration. However, the MAC continued to review any pre-claim review requests that were submitted.
CMS expects to discontinue exercising enforcement discretion beginning on August 3, 2020, regardless of the status of the public health emergency. CMS will resume demonstration operations in all states. The initial choice selection period will begin in North Carolina and Florida on August 3, 2020 and end on August 17, 2020. The choice selection period for Ohio’s second review cycle will also begin August 3, 2020 and end on August 17, 2020.
Following these choice selection periods, home health claims 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 terms of the choice selected by the provider. This includes pre-claim review, prepayment review, post payment review, or any applicable 25% payment reduction.
Following the resumption of the demonstration, the MAC will conduct post payment review on claims subject to the demonstration that were submitted and paid during the pause. CMS will work with affected providers to develop a schedule for post payment reviews that does not significantly increase provider burden. Claims that received a provisional affirmative pre-claim review decision and were submitted with an affirmed Unique Tracking Number (UTN) will continue to be excluded from most future medical review. CMS will provide additional details about the choice period on its demonstration website.
COST REPORTING COVERING COVID-19 PHE
Home health agencies (“Agencies”) received Provider Relief Funding and many received proceeds from PPP SBA Guaranteed Loans.
Agencies should be tracking COVID-19 PHE expenses chargeable to Provider Relief Funding separately in their accounting records, but in a manner consistent with the required reporting components and cost centers of the Home Health Agency Cost Report. This will allow the Agency to separately report these COVID-19 PHE expenses or combine these expenses with other expenses in the appropriate cost center as mandated by the cost reporting forms and instructions. Telehealth expenses should be segregated and reported as an Administrative and General expense in accordance with previously issued instructions.
Barring any further cost reporting instruction, The Health Group, LLC will not offset any PPP loan forgiveness or Provider Relief Funding from allowable costs in accordance with existing cost reporting rules and instructions. However, these revenues will be separately disclosed and reported as part of the cost report submission.
Cost report information is used in rate setting. Accordingly, ongoing home health agency costs should not be reduced by CMS for any PPP loan forgiveness and, even with additional CMS guidance, should it be issued, costs should not be reduced below levels of ongoing home health expenses. We are hopeful that any CMS COVID-19 PHE cost reporting instructions that may be issued allow CMS to identify revenue assistance during the COVID-19 PHE but do not cause agencies to understate ongoing costs of home health activities. The Health Group, LLC will monitor this issue closely and continue to report any changes. Agencies, like other providers, should monitor any changes regarding Provider Relief Funding (CARES Act Provider Relief Fund) here.