On January 1, 2022, the Centers for Medicare and Medicaid Services (CMS) implemented its plan to eliminate home health pre-payments by eliminated submission of Request for Anticipated Payment (RAPs) and moving to a one-time submission of a Notice of Admission (NOA) to alert CMS when a patient has been admitted to home health. Unfortunately for home health agencies, all three Medicare Administrative Contractors (MACs) have experienced issues with rejections of NOAs almost immediately. While it is frustrating, CMS and MACs are working diligently to address issues in the first few months of NOA implementation.

To date, there have been multiple issues processing NOAs, with multiple reasons codes for rejecting the NOA, some of those codes are:

• U537F: The Common Working File (CWF) does not correctly recognize a discharge (patient status other than 30 on the last HH period).
• E46#U: These edits are assigning on home health adjustment claims where the original claim had a late request for anticipated payment penalty resulting in a full reduction and the VC 64 amount was 0.00. The VC 64 is not being retained on the adjustment claims, even when manually entered into the claim.
• 32114: An issue with ZIP Codes submitted on Electronic Media Claims (EMC) has been identified for all Medicare Administrative Contractors, causing it to incorrectly return to provider.

NGS Updates to NOA

On February 15, NGS the Medicare Administrative Contractor for Home Health and Hospice Regions J6 and JK hosted a “Coffee Break” to answer questions about the new Notice of Admissions (NOA) process. NGS staff shared the link to additional FAQs on the Notice of Admission Process for home health agencies to navigate the new process. At this time there are NGS has no resolutions to these errors however, when a resolution is identified, NGS will post on the Productions Alert section of their website and mark the alert as “closed”, along with sending an email notification.

During the call, multiple providers cited issues with using Condition Code 47 on an NOA and having it Returned to Provider (RTP). NGS staff clarified that this code should be used for transitions from one home health provider to another or if the patient discharged from one home health agency, but the first agency had not yet submitted their final claim. Staff advised that if providers continue to have issues with the condition code being rejected, they should reach out to the Provider Contact Center with examples so this issue can be added to the Production Alerts as well.

Provider also asked NGS staff for clarification on the process of canceling an NOA with an incorrect admission date. Unfortunately, it can take several days for an NOA to cancel, meaning you cannot cancel an incorrect NOA and resubmit a corrected NOA on the same day. Staff advised providers to resubmit when they see a PB996 or PB997 status.

One final topic addressed during the call was whether or not the CMS or the MACs planned to allow corrections to NOAs with an incorrect date in the future. At this time there is no plan to allow for corrections to existing NOA and the expectation will be to cancel the incorrect NOA and resubmit. This follows the same process as the original Request for Anticipated Payment (RAP) process that NOAs replaced.

Additional MAC Resources

While this information is helpful for many home health agencies, each MAC conducts business differently which means you will need to refer to your own MAC’s reason code correction pages, resources, and provider contact centers. LeadingAge will continue to monitor and advocate for quick resolutions to implementation issues with NOA.

Notice of Admission FAQs and Guidance by MAC

Palmetto: Home Health Notice of Admission (NOA) Frequently Asked Questions (FAQ)

NGS: Notice of Admission Questions and Answers

CGS: Billing the Home Health Notice of Admission, Tips for HH NOAs

Tracking Notice of Admissions Reason Code Corrections

Palmetto: Claims Payment Issues Log

NGS: Productions Alert

CGS: Claims Processing Issues Log

Provider Contact Centers

Palmetto: Provider Contact Center

NGS: Provider Contact Center

CGS: Home Health and Hospice Customer Service