Good Morning to All MFS Bloggers, Pursuant to CMS, its Change Request 7080 established the policy that for institutional claims that include span dates of service (i.e., a ‘From’ and ‘Through’ date span on the claim), the ‘Through’ date on the claim is used to determine the date of service for claims filing timeliness. This policy had an unintended impact on billing home health Prospective Payment System (HH PPS) episodes of care.
Medicare instructions require the ‘From’ and ‘Through’ dates to be the same date on the request for anticipated payment (RAP) for an HH PPS episode. This means the RAP will have an earlier ‘Through’ date than the associated final claim for the same episode. Since CR 7080 was implemented, RAPs have been rejected as untimely when the associated final claim was still timely. CMS has determined that this is an error and has instructed Medicare contractors to bypass the enforcement of timely filing on RAPs.
Cases have already occurred in which a RAP was incorrectly rejected as untimely and a timely-submitted final claim for the same episode was returned to the provider due to the lack of a corresponding RAP on file. In some cases, these final claims are now past the timely filing deadline. CMS has determined that an administrative error exception to the timely filing requirement applies in these cases. Home health agencies affected by these cases should bring them to the attention of their Medicare contractors, who will bypass timely filing for these claims so they may be processed.
Have a great day! CP
