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Volume 20.03

With the implementation of PDGM, newly certified home health agencies (new providers), certified after January 1, 2019, are not entitled to receive partial episode payment based on a Request for Anticipated Payment (“RAP”).  Recently, CMS has clarified that “New” providers has a broader definition.

New providers include those agencies filing a CMS 855A as a Change of Ownership (“CHOW”) and those agencies filing a CMS 855A as a Change of Information (“COI”) when there has been a 100% equity ownership transfer.  In the case of a CHOW or applicable COI filing, RAP payments will be suppressed for a provisional period of enhanced oversight.

The period of enhanced oversight will be between 30 days and one year and applicable providers will be notified by CMS or the Medicare Administrative Contractor regarding the following:

  • The date on which the provisional period of enhanced oversight will be effective for the HHA and when it will end,
  • Notice that while the HHA is in the provisional period of enhanced oversight all RAP payments will be suppressed, and
  • Notice that the HHA still needs to submit a RAP for each home health episode to ensure the final claim is processed.

Details are available here.



Each year, the National Government Services Home Health and Hospice (HH+H) team hosts a Medicare Summit in Las Vegas, Nevada. This year, the focus will include Part A and Part B providers to give an overall picture on how all Medicare providers affect each other. This summit will offer a unique educational opportunity to all Medicare providers to hear from the Medicare Administrative Contractors (MACs) who administer the program along with National Associations who support the Medicare Program. There will be several educational offerings for HH+H providers, as well as information detailing how the different areas of Medicare intertwine in caring for patients treated under the HH+H benefits. The 2020 Medicare Summit attendees will receive education from the MACs collaborating to address the most current Medicare issues. This year’s program will be held at the RIO Conference Center, (3700 West Flamingo Road, Las Vegas, Nevada) on September 23-24, 2020. Registration will open on April 1, 2020, visit here to register at the earliest possible date.  The 2019 program sold out early.


Don’t forget about the NAHC Financial Management Conference and Expo scheduled for July 26-28, 2020 in Las Vegas and the Home Care and Hospice Conference and Expo scheduled for October 18-20, 2020 in Tampa, Florida.  Details are available here.