On January 1, 2022, the Centers for Medicare and Medicaid Services (CMS) implemented its plan to eliminate home health pre-payments which occurred through submission of Request for Anticipated Payment (RAPs) CMS moved to a one-time submission of a Notice of Admission (NOA) that alerts them when a patient has been admitted to home health. The process will be fully implemented by May 26, 2022.

To fully implement the policy, CMS has made multiple updates to Medicare manuals to clarify policy, and claims processing expectations. In the first revision to the Medicare Benefit Policy Manual which was issued in March, an accompanying MLN article incorrectly summarized regulations for advanced nurse practitioners to certify eligibility and order services for home health. After advocacy efforts from LeadingAge in collaboration with the home health and advanced practice nurse community, the information has been revised.

Unfortunately for home health agencies, despite the revision to policy and claims manuals 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.

Medicare Manual Updates

Home Health Medicare Benefit Policy Manual: CMS updated a change order request to the Medicare Benefit Policy Manual to clarify the NOA process, establish the requirements for NOA submission, and clarify the definition of an allowed practitioners. An MLN article was also updated to review the changes and expectations for new NOA process.

Home Health Claims Processing Policy: CMS issued a change request removing the requirement to submit an NOA before billing for home health denial notices. Before the implementation of NOA on January 1, 2022, every claim for home health period required the submission of a Request for Anticipated payment except billings for denial notice (TOB 320 reporting condition code 21). Due to a CMS oversight in the implementation of NOA, billing for denials were not excluded from the requirement to submit an NOA. The CR submitted this month will correct this error and providers will no longer be required to submit an NOA with billing for denials.

NOA Rejection Codes

To date, there have been multiple issues processing NOAs, with multiple reasons codes for rejecting the NOA. The list below describes the reason for each of the error codes. The table outlines which error codes do not yet have a resolution and which error codes do have a resolution and the instructions for providers when resubmitting rejected billing.

• U537F: The Common Working File (CWF) does not correctly recognize a discharge (patient status other than 30 on the last HH period).
• 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.
• 31254: Home Health NOA were assigned an incorrect Julian date (i.e. year-day-month) in the Document Control Number (DCN) and returned to the provider (RTP’d) with reason code 31254 in error.
• U5235: Home Health NOAs with an admission date that falls within a hospice period are rejecting with reason code U5235 in error.
• E46#U (E460U-E469U): 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.

NOA 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, Untimely NOA Exception Requests Received in Error

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